1. Revocation of the first instance judgment.

2. The Defendant’s value-added tax amounting to KRW 613,420,940, which was assessed against the Plaintiff on November 1, 2016.

1. Details of the disposition;

A. From December 1, 2010 to June 29, 2016, the Plaintiff is a company closed ex officio by the head of the competent tax office, while engaging in scrap metal wholesale and steel retail business in Daegu Dong-gu, Daegu-gu, etc.

B. The Plaintiff received a tax invoice of KRW 3,768,727,100 (hereinafter “instant tax invoice”) from C during the taxable period of value-added tax from the first period (from January 1 to June 30), 2014 to the second period (from July 1 to December 31, 2014).

As indicated below, the Plaintiff deducted the quarterly input tax amount including the input tax amount under the tax invoice of this case from the quarterly output tax amount of each quarter, and declared and paid the first half of 2014 and the second half of 2014.

No. 385,753,676, 376, 331, 495, 114, 4839, 4839, 175, 745, 400, 665 31, 758, 218 22, 963, 510, 214, 385, 114, 4839, 422,181 (units:)

C. From July 11, 2016, the Defendant’s damage

9. As a result of the tax investigation conducted against the Plaintiff by November, 19, it determined that the actual supplier of scrap metal transactions under the instant tax invoice constitutes a tax invoice in which the registration number and name or title of the supplier are written C, even though I (F) and thus, the instant tax invoice constitutes a tax invoice in which the registration number and name or title of the supplier are written differently from the fact.

Accordingly, on November 1, 2016, the Defendant did not deduct the input tax amount under the instant tax invoice from the output tax amount pursuant to Article 39(1)2 of the Value-Added Tax Act, but notified the Plaintiff of the correction and notification of the amount of value-added tax of KRW 613,420,940 (including the additional tax) and value-added tax of KRW 80,844,440 (including the additional tax) for the year 2014.

(hereinafter “instant disposition”) D.

On April 19, 2017, the Plaintiff dissatisfied with the instant disposition and filed an appeal with the Tax Tribunal on April 19, 2017, but on July 2017.