The judgment of the court below is reversed.

Defendant shall be punished by a fine of KRW 20,000,000.

The above fine shall not be paid by the defendant.

1. The summary of the grounds for appeal is that the lower court found the Defendant guilty of the instant facts charged, or erred by misapprehending the legal principles, which affected the conclusion of the judgment, even though the Defendant actually provided construction services to DBA and submitted a list of total tax invoices by customer.

2. Determination

(a) No person who is the summary of the facts charged of this case may submit to the Government a false list of invoices by seller or seller under the Value-Added Tax Act without supplying or receiving goods or services.

(1) On July 25, 2013, the Defendant filed a final return on the tax invoice by purchaser at the Busan District Tax Office located in 263, as the superintendent of Busan District, on July 25, 2013. The Defendant filed a final return on the tax invoice by purchaser. The facts are as follows: (a) although there was no supply of goods equivalent to KRW 100,000 from C, a false statement on the tax invoice by purchaser was made to the public official in charge of the relevant tax office; and (b) on January 25, 2014, the Defendant filed a final return on the tax invoice by purchaser at the above North District Tax Office as of January 25, 2013, stating the false statement on the tax invoice by purchaser to the public official in charge of the said tax office, stating the false statement on the tax invoice by purchaser as to the supply of goods equivalent to KRW 288,00,000,000, and submitted the final return on the tax invoice by purchaser to the public official in charge of the said tax office.

The Defendant submitted a list of the separate accounts accounts of each of its false re-sales units on July 25, 2013, when filing a final return of value added at the office of Busan, such as the foregoing paragraph 1, at the Busan, the office of tax offices in Busan, the same as the foregoing, and the facts are as follows: (a) even though there was no supply of goods equivalent to KRW 85,00,000 in the D.C. and KRW 91,309,000 in the E., and there was no supply of goods equivalent to the same amount.