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Bail Denied Due to Massive GST Evasion Through Online Gaming Routes

Case Law Details

TaxGuru Citation
2026 taxguru.in 5
Case Name
Manoj Kumar Vs State of Rajasthan (Rajasthan High Court)
Date of Judgement/Order
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Manoj Kumar Vs State of Rajasthan (Rajasthan High Court)

The Rajasthan High Court dismissed the bail applications filed by the accused in a case involving alleged large-scale GST evasion through online gaming transactions, holding that the gravity, scale, and nature of the allegations attracted the stringent rigour of Section 132 of the Central Goods and Services Tax Act, 2017. The applications challenged the rejection of regular bail by the Sessions Courts in connection with offences under Sections 132(1)(i) and 132(5) of the CGST Act, arising from an investigation by the Directorate General of GST Intelligence (DGGI).

According to the prosecution, the accused acted as facilitators for onboarding multiple private companies with online payment aggregators, enabling receipt of online gaming revenues without payment of GST. The investigation revealed that these entities routed substantial sums through UPI IDs and virtual payment addresses, while filing NIL GST returns and failing to discharge tax liabilities. The alleged evasion, initially quantified at ₹11.20 crore, was later revised in the final complaint dated 10.11.2025 to approximately ₹95.77 crore, based on admitted collections of about ₹53.21 crore in one company and further collections running into hundreds of crores through other entities, resulting in massive tax loss.

The applicants were arrested on 12.09.2025 following search and seizure operations under Section 67(2) of the CGST Act and recording of statements under Section 70. During investigation, statements allegedly revealed that company credentials were shared for commission, multiple companies were onboarded with payment aggregators, and there were communications with an individual claimed to be based abroad. The prosecution argued that the offences were cognizable and non-bailable, involved enormous financial transactions, and carried a serious risk of tampering with electronic evidence, influencing intermediaries, and absconding.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,275

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