The judgment of the court below is reversed.

A defendant shall be punished by imprisonment for a year and a fine of 650,000,000 won.

The above fine shall be imposed on the defendant.

1. Summary of grounds for appeal;

A. Legal principles or misunderstanding of facts 1) When the Defendant issues and receives false tax invoices as the Defendant, submission of a tax invoice shall be deemed as an act accompanied by punishment, in which the tax invoice is issued and received. As such, adding the amount entered in the aggregate of the tax invoice to the “total amount of supply values, etc.”, which is the standard for aggravated punishment pursuant to Article 8-2 of the Act on the Aggravated Punishment, etc. of Specific Crimes, apart from the amount entered in the tax invoice issued and received, constitutes double punishment.

Even if the submission of a list of total tax invoices does not constitute a violation due to the issuance and reception of false tax invoices.

Even if the act of submitting a tax invoice is already included in the act of issuing tax invoice, the submission of a list of total tax invoice and the issuance and receipt of tax invoice should be deemed as one of the act of submitting a list of total tax invoice and calculating the above "total amount of supply price,

Therefore, the sum total of the tax invoices submitted by the Defendant should not be added to calculating the above “total sum of the supply values, etc.”.

2) After issuing a false tax invoice, the Defendant cancelled each sales and purchase KRW 810,000,000 for each purchase before submitting a list of total tax invoices and issued a revised tax invoice, and the issuance of the revised tax invoice does not constitute a crime.

Nevertheless, the lower court erred by misapprehending the legal doctrine or by misapprehending the facts charged in the instant case.

B. The sentence of the lower court (one year and six months of imprisonment, and fine of KRW 970,00,000, etc.) is too unreasonable.

2. Judgment on the misapprehension of legal principles or the assertion of mistake of facts

A. 1) As to the assertion that dual punishment or the submission of a list of total tax invoices and the issuance and reception of tax invoices should be regarded as one act, the same transaction is identical to the relevant legal doctrine.