All the judgment below is reversed.

The Defendants are not guilty. The summary of the judgment of innocence against the Defendants is published.

1. Summary of grounds for appeal;

A. The lower court erred by misapprehending the legal doctrine or by misapprehending the legal doctrine, which found the fact that Defendant A manufactured and sold fake petroleum. In so determining, the lower court erred by misapprehending the facts or by misapprehending the legal doctrine, thereby convicting the Defendant A of the facts charged.

B. In light of the sentencing conditions of this case, the sentence of the lower court against the Defendants (Defendant A: 10 months of imprisonment, Defendant B: 50 million won) is too unreasonable.

2. Facts charged;

A. Defendant A is a person who operates a stock company B established for the purpose of selling petroleum in Songpa-gu Seoul Metropolitan Government.

No person shall evade taxes by manufacturing or selling fake petroleum products.

Nevertheless, around January 2012, the Defendant manufactured and sold fake petroleum 26,218 liters in a manner of mixing lux oil with lux oil while supplying light oil used as a raw material to construction machinery at the construction site using Defendant’s oil tank at the construction site by using Defendant’s company around January 2012, and subsequently evaded taxes equivalent to KRW 1,016,876,374 in total by manufacturing and selling fake petroleum equivalent to the total amount of KRW 3,04,042 liters, as stated in the list of crimes in the attached Table, between the aforementioned date and December 2014.

B. Defendant B, at the date and time and place set forth in paragraph 2. A, Defendant B, the representative of the Defendant, evaded taxes as described in paragraph 2. A. on the Defendant’s business.

3. Judgment on the misapprehension of facts and misapprehension of legal principles

A. The evidence as shown in the facts charged in the instant case and the evidence presented by the lower court that conforms to the facts charged in the instant case are “the evidence, such as part of the H’s legal statement, I’s legal statement, J’s statement to the investigative agency, and transaction account books.”

The summary of the above evidence is the quantity of light oil sold calculated based on the actual volume of light oil purchased, transaction account books, details of supply, etc. calculated based on the purchase tax account statement, etc.