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Issues: Whether the applicant was entitled to regular bail in connection with the alleged offence under the Gujarat Goods and Services Tax Act, 2017.
Analysis: The application was considered under Section 439 of the Code of Criminal Procedure, 1973 in the context of an alleged GST offence. The investigation had concluded and the complaint or charge-sheet had been filed. The case was stated to rest primarily on documentary evidence, the alleged punishment was not shown to require continued custody at that stage, and the prosecution had not established that the applicant was likely to tamper with evidence. The Court also considered the period of custody, the attributed role, the quantum of alleged tax evasion, and the proposed deposit of an amount as a condition for release.
Conclusion: The applicant was held entitled to regular bail, subject to payment and compliance with the imposed conditions.
Final Conclusion: Bail was granted with conditions, and the applicant was ordered to be released on execution of the prescribed bond and compliance with the monetary and reporting requirements.
Ratio Decidendi: Where investigation is complete, the case is substantially documentary, and no adequate risk of tampering with evidence is shown, regular bail may be granted even in a GST prosecution, subject to appropriate conditions.