2. The defendant alleged the same argument as the reasons for appeal in the court below, and the court below rejected the above argument by making a detailed statement on the judgment. In full view of the following circumstances, the court below's decision is justified and it cannot be said that there was an error of misconception of facts, and the defendant's assertion is without merit.

① The Defendant’s “D” reported the volume of KRW 1.2 billion as the average quarterly sales in the year 201 are merely KRW 10,200,000,000,000. On the other hand, the purchase amount exceeds KRW 65,00,000,000, which is the same level as the previous sales amount, and the difference between the sales amount and the purchase amount is unusually large.

On the other hand, the Defendant was delinquent in paying value-added tax exceeding KRW 100 million since February 2010, which was the transferor, but closed the business ex officio after checking the place of business on October 26, 201 from the Suwon Tax Office on the spot and investigated the said place of business in detail.

② Defendant’s operation “D” was mainly a place of business where a panel or H beamline, which is a building material, is supplied to a building business entity or a man-made business entity.

However, the contract concluded between “D” and Korea Heavy Industries and Korea Co., Ltd. as indicated in the facts charged of the instant case is respectively a container lifts panel work, a set panel work (factory reinforcement work). According to the Defendant’s assertion, the said construction is the establishment of sn beamline and the assembly of a panel. As such, the Defendant could have been supplied with materials, such as a considerable quantity of panels.