The legitimacy of the assertion that the actual purchase of steel on this disposition by processing transaction and approval by bill is made;

If, as a result of the tax investigation, the sales office was identified as data, and the representative clearly expresses that the tax invoice of this case is due to the processing transaction in the course of the investigation, it is reasonable to deem that the tax invoice is a processed tax invoice issued without the actual transaction.

Article 17 of the Value-Added Tax Act

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The judgment of the first instance is revoked. The defendant's imposition of value added tax of 20,67,210 won on 204 against ○ Steel Co., Ltd. on November 1, 2006 and the notification of change in the income amount of 20,67,210 won shall be revoked, respectively.

The key issue of the instant case is whether the instant tax invoice is a processed tax invoice issued without real transaction.

As to this, the first instance court held that: (a) the Plaintiff issued a promissory note with ○ Steel as the addressee prior to the purchase of the goods in relation to the transaction of issuing the tax invoice of this case; (b) the transaction itself is an exceptional part of this transaction; and (c) the promissory note does not have any endorsement of ○ Steel; and (c) the Plaintiff requested ○○ Steel to purchase kyl-day at the “○○○○○ Department” upon receipt of the said bill; and (c) the Plaintiff transferred the said bill through ○○○○○ Branch, the actual manager of the said ○○ Group, but the transaction was not confirmed at around September 16, 204, the day of endorsement; (c) the fact that the transaction was between ○○ Steel and ○ Steel was not verified; (d) the result of the tax investigation was revealed as data; and (e) the representative clearly stated that the tax invoice of this case was due to the processing transaction during the investigation process; and (e) the instant notice of the tax invoice of this case and its additional disposition were justifiable.

Therefore, the reason why this court is used in this decision is not consistent with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure Act, except for the addition of "the testimony on Kim○-○" at the court after the statement of No. 9-1 of the evidence No. 7 of the judgment of the court of first instance, which is not consistent with this decision, as evidence.

Therefore, the judgment of the first instance is just, and the plaintiff's appeal is dismissed as it is without merit, and it is so decided as per Disposition.