For the reasons indicated in its holding, the lower court reversed the first instance judgment convicting the Defendants on the part of the violation of the Punishment of Tax Evaders Act due to the evasion of value-added tax arising from transactions with M, N, S, and O, on the grounds that there is no proof of crime, and acquitted the Defendants.

The judgment below

Examining the reasoning in light of the record, the lower court did not exhaust all necessary deliberations as stated in the grounds of appeal and did not err by misapprehending the bounds of the principle of free evaluation of evidence against logical and empirical rules or by misapprehending the legal doctrine on criminal intent of tax evasion.

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