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Issues: Whether the accused-petitioner was entitled to bail in a prosecution under Section 132(1)(i) of the Assam GST Act, 2017 after completion of investigation and filing of the offence report.
Analysis: The application was considered in the context of the seriousness of the alleged tax evasion, the fact that the offence was treated as an economic offence, the completion of investigation, and the settled principles governing bail. The Court weighed the nature of the accusation, the severity of punishment, the absence of any apparent need for further custodial interrogation, and the lack of material suggesting that release would lead to abscondence or tampering with evidence. The Court also noted that the petitioner had remained in custody for 65 days during investigation.
Conclusion: The petitioner was held entitled to bail.
Ratio Decidendi: Where investigation is complete and there is no material showing a risk of abscondence or interference with evidence, bail may be granted in an economic offence, subject to suitable conditions, even though the allegation is serious.