The judgment of the court below (including the portion not guilty) shall be reversed.

The defendant is not guilty. The summary of the judgment against the defendant.

1. Summary of grounds for appeal;

A. Defendant 1) misunderstanding of the facts and misapprehension of the legal doctrine) The Defendant, who actually operates C Co., Ltd. (hereinafter “C”), traded with D Co., Ltd. (hereinafter “D”) and G Co., Ltd. (hereinafter “G”), was issued a tax invoice in the form of electronic tax invoice.

Article 10(3) of the Punishment of Tax Evaders Act and Article 8-2 of the Act on the Aggravated Punishment, etc. of Specific Crimes (hereinafter “The Aggravated Punishment Act of Specific Crimes”) which punishs the submission of a list of total tax invoices by seller is punished against the act of violation on the premise that the act of violation is not subject to the submission of a list of total tax invoices by seller. The Added Tax Act is exempted from the obligation to submit a list of total tax invoices by seller when the electronic tax invoices are received. As such, as long as the Defendant receives the purchase tax invoices from D and G in the form of electronic tax invoices, it is exempt from the submission of a list of total tax invoices by seller. Therefore, even if the Defendant submitted a false list of total tax invoices by stating the false list to the government, there is no room to establish a crime of violation of the Punishment of Tax Evaders Act or the crime of aggravated punishment

In fact, the Defendant submitted a list of total tax invoices by seller to the government, and did not enter the details of purchase transaction with D and G, in which electronic tax invoices were received, in the list of total tax invoices by seller. The Defendant did not directly submit the list of total tax invoices by seller on the details of purchase transaction with D and G.

B) The Defendant actually purchased the relevant weights from D and G and issued a tax invoice for purchase, and all transaction details entered in the list of total tax invoices for individual suppliers are based on the purchase tax invoice that conforms to the actual transactional relationship.

However, the item is not "Dong" on the tax invoice issued by the defendant.