Questão jurídica principal
Whether the refusal to unseal was based on a sufficient suspicion of tax forgery and document falsification
Decisão extraída
Yes. The existing record showed concrete and contradictory indications requiring review of the seized accounting and audit documents.
Fundamentação extraída
The Federal Court held that it was enough that the material raised concrete suspicion of offences and that the seized documents were relevant to clarify inconsistencies; the lower court had assessed the evidence too narrowly.