1. The defendant's appeal is dismissed.

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

Purport of claim and appeal

[Claim]

1. The reasoning of the judgment of the court of first instance cited in this case is as stated in the corresponding part of the judgment of the court of first instance, except for the part added as follows. Thus, it shall be cited as it is in accordance with Article 8(2) of the Administrative Litigation Act and Article 420 of the Civil Procedure

2. The following contents are added at the end of 7th page 12, the following at the end of the instant original disposition [In short, the purport of the instant decision is to re-examine whether the Plaintiff’s duty-free oil transaction was actually conducted against farmers, who are the counterparty, solely on the ground that “the Plaintiff’s payment was made at intervals of one minute on the cards transaction records at the Hansan branch, Seosan Branch, Nonghyup, the Plaintiff submitted by the Plaintiff, and the credibility of the data is not verified.”

However, after the decision of this case, the defendant investigated only two of nine farmers who are the other party to the transaction.

On the other hand, according to the letter of confirmation received as a result of the investigation, although the vehicle transporting duty-free oil has a vehicle different from the trading gas station, it is the purport that the plaintiff and the farmers have the duty-free oil itself and have paid the price by the card, etc.

As alleged by the Defendant, according to the record of transaction situation (A) objectively confirmed, it is true whether the Plaintiff had a duty-free duty to supply the transaction in question.

However, considering these factors comprehensively, in order to determine that the Defendant’s transaction of duty-free oil claimed by the Plaintiff is the most active transaction in accordance with the purport of the instant decision while taking into account the aforementioned factors, the remainder as to whether the Plaintiff actually sold the duty-free oil or whether the Plaintiff actually sold the duty-free oil as stated in the instant decision.