All appeals by the Defendants are dismissed.

1. Summary of grounds for appeal;

A. (1) In misunderstanding of facts, the Defendants filed a false declaration on the dutiable value on the basis of the price actually paid or payable to F, an exporting company, in filing each import declaration of this case.

(2) The cost of processing the imported goods of this case determined by the Defendants and “F” is not for tariff evasion, and is not for tariff evasion, and does not provide any property interest other than the agreed contractual processing cost. Defendant A did not have an intention to make a false declaration of the dutiable value at the time of filing the import declaration of this case.

(3) The Defendant Company re-exports the blood pressure system produced by processing the instant imported goods and thereby refund the customs duties paid at the time of the import declaration. Even if “F” filed an import declaration after including secondary materials purchased in China, the customs duties paid by re-exporting the imported goods can be refunded. As such, there is no reason to evade customs duties by filing a false import declaration on each of the instant imported goods at the time of the import declaration.

In addition, if customs are reduced, the corporate tax of the defendant company is increased, so there is no benefit to evade customs duties.

Therefore, the Defendants did not have the purpose of evading the customs duty of this case.

B. The sentence (each of eight million won) imposed by the lower court on the Defendants of unreasonable sentencing is too unreasonable.

2. Determination

A. (1) Determination of the assertion of mistake of facts is, in principle, a tax return and payment method. According to Article 30(1) and Article 30(3)4 of the former Customs Act (amended by Act No. 11602, Jan. 1, 2013; hereinafter the same), customs duties shall be determined on the basis of the price actually paid or payable by a buyer in accordance with Article 30 on the determination of the dutiable value of imported goods, and the buyer and buyer.