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Where did he get chakra to summon it? We know Naruto needed even Kurama's chakra to summon Gamabunta.
How do you know he was out of chakra? He could have just deactivated his Sharingan since he had just defeated Deidara (yes Sasuke making his enemy resort to suicide counts as his victory) and arrogantly didn't see him as threat anymore.
Yes, I see the argument that is somewhat of a deus ex machina but it does make some sense.
