The lower court found the Defendant guilty of the instant charges on the grounds indicated in its reasoning.

The judgment below

Examining the reasoning in light of the relevant legal principles and evidence duly admitted, the lower court did not err in its judgment by exceeding the bounds of the principle of free evaluation of evidence against logical and empirical rules, or by misapprehending the legal doctrine on “tax evasion” under Article 5 of the Punishment of Tax Evaders Act and “act

Although the defendant asserts that Article 5 of the Punishment of Tax Evaders Act is unconstitutional, it cannot be said that the above provision violates the principle of prohibition of double punishment and the principle of prohibition of excessive punishment under the Constitution.

Therefore, the appeal is dismissed. It is so decided as per Disposition by the assent of all participating Justices on the bench.