This compilation indexes twelve High Court orders — decided between April 2025 and July 2026 — in which accused persons filed bail applications under the criminal prosecution provisions of the Central Goods and Services Tax Act, 2017, primarily engaging Section 132(1)(b). The rulings span the Allahabad, Punjab-Haryana, Chhattisgarh, Gauhati, and Orissa High Courts and collectively illustrate the range of fact patterns, enforcement agencies (DGGI, CGST Commissionerates), and procedural postures arising in fake-invoice and fraudulent Input Tax Credit (ITC) prosecutions. This index is intended for in-house tax counsel, Big-4 associates, and legal researchers tracking enforcement trends under the CGST Act's penal chapter.

Research index only. This page is a structured case-law reference compiled from publicly available judicial orders. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers must verify all information against the full text of the relevant judgment and consult qualified counsel before acting on any matter.

The statutory framework in one paragraph

Section 132 of the Central Goods and Services Tax Act, 2017 creates a set of cognizable and non-cognizable criminal offences relating to GST evasion. Section 132(1)(b) specifically targets the offence of fraudulently availing, or attempting to avail, Input Tax Credit in excess of the credit to which the person is entitled under the Act. The provision prescribes graduated punishment depending on the amount of tax evaded or the credit wrongly availed: where the amount exceeds five hundred lakh rupees, the offence is punishable with imprisonment for a term which may extend to five years along with a fine; for amounts between two hundred lakh and five hundred lakh rupees, imprisonment may extend to three years; and for amounts up to two hundred lakh rupees, imprisonment may extend to one year. Section 132(5) makes offences involving amounts above five hundred lakh rupees cognizable and non-bailable. Prosecutions under this chapter are typically initiated by the Directorate General of GST Intelligence (DGGI) or CGST Commissionerates following investigation, and complaints are filed before judicial magistrates under the relevant provisions of the Bharatiya Nagarik Suraksha Sanhita, 2023 (which replaced the Code of Criminal Procedure).

The 12 rulings

1. Shivam Dwivedi vs Union Of India And 2 Others

Bench: Allahabad High Court
Date: 21 July 2026
Sections engaged: 132(1)(a), 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant, described as the Proprietor of M/s Kamadgiri Trading Company, was prosecuted pursuant to a complaint preferred before the Chief Judicial Magistrate, Meerut, under Sections 132(1)(a) and 132(1)(b) of the CGST Act, 2017. The prosecution alleged that the company purchased Areca Nuts in bulk from Assam and Karnataka, and that discrete verification revealed that recipient trading firms — including M/s Ganga Trading Company and M/s Kamtanathji Traders — had no retail infrastructure, raising allegations of circular or fictitious transactions. The bail application (Criminal Misc. Bail Application No. 15773 of 2026) was reserved on 6 July 2026 and delivered on 21 July 2026; the final disposal direction is not specified in the source preview.

2. Kamalpreet Singh vs State(Directorate General Of GST

Bench: Punjab-Haryana High Court
Date: 19 May 2026
Sections engaged: 132(1)(b), 132(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed a regular bail petition (CRM-M-73660-2025) before the Punjab and Haryana High Court in connection with case No. IINT/COMP/3/2025-GROUP-E of the office of ADG-DGGI-ZU-Chandigarh, dated 11 September 2025, engaging Sections 132(1)(b) and 132(5) of the CGST Act, 2017. A co-application (CRM-6655-2026) for preponing the date of hearing was dismissed as having been rendered infructuous at the outset of the order. The substantive bail petition remained for consideration per the source preview, and no final disposal direction is recorded in the available text.

3. Aman Kumar Agrawal vs Union Of India

Bench: Chattisgarh High Court
Date: 17 March 2026
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed his first bail application (MCRC No. 1519 of 2026) under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 before the High Court of Chhattisgarh at Bilaspur, arising from his arrest in connection with Crime No. AD2212250057378B dated 20 December 2025 (File No. DGGI/INV/GST/2955/2025-GR.VI) by DGGI Zonal Unit Raipur. The prosecution alleged that the applicant fraudulently availed Input Tax Credit by issuing fake invoices amounting to ₹8,57,15,507/-, with fake e-way bills generated and invoices issued in the names of entities including M/s Mahalaxmi Enterprises, M/s Prem Enterprises, and M/s Shri Exim. The final disposal direction is not specified in the source preview.

4. Naveen Tayal vs Central Goods And Service Tax

Bench: Punjab-Haryana High Court
Date: 7 March 2026
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner sought regular bail in complaint case bearing COMA No. 518 of 2025, District Faridabad, dated 5 July 2025, filed by the Superintendent, CGST Commissionerate, Faridabad. The allegations stated that the petitioner and a co-accused were involved in issuance of fake invoices so as to avail and pass on ineligible input tax credit without actual supply of goods or services. The bail petition (CRM-M No. 69856 of 2025) was decided on 7 March 2026; the disposal direction is not recorded in the source preview.

5. Manmohan Singh Sapra vs State Of Ut Chandigarh, Dg Of GST

Bench: Punjab-Haryana High Court
Date: 15 December 2025
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner was taken into custody on 28 May 2025 in connection with case No. INT/7-2005-Group-E of the office of ADG-DGGI-ZU-Chandigarh, alleging commission of offences under the CGST Act, 2017. The bail petition (Criminal Misc. No. M-38179 of 2025) was reserved on 16 October 2025 and pronounced on 15 December 2025; the court's order references, among other authorities, the Supreme Court decisions in Y.S. Jagan Mohan Reddy v. CBI (2013) 7 SCC 439, Adri Dharan Das v. State of West Bengal (2005) 4 SCC 303, and Radhika Agarwal v. Union of India (2025) 6 SCC 545, and notes that the maximum punishment prescribed for the offence is imprisonment up to five years and that investigation in the case was already complete. The final disposal direction is not specified in the source preview.

6. Baldeep Singh Sapra vs State (Directorate General Of GST

Bench: Punjab-Haryana High Court
Date: 15 December 2025
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner was similarly implicated in case No. INT/7-2005-Group-E of the office of ADG-DGGI-ZU-Chandigarh and taken into custody on 28 May 2025, with the bail petition (Criminal Misc. No. M-47385 of 2025) reserved on 12 November 2025 and pronounced on 15 December 2025. As with the co-matter decided the same day, the court's order references Y.S. Jagan Mohan Reddy v. CBI (2013) 7 SCC 439, Adri Dharan Das v. State of West Bengal (2005) 4 SCC 303, and Radhika Agarwal v. Union of India (2025) 6 SCC 545, and notes that the maximum punishment is imprisonment up to five years and that investigation was already complete. The final disposal direction is not specified in the source preview.

7. Deepak Kumar vs Union Of India

Bench: Allahabad High Court
Date: 4 November 2025
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The order recorded in the source preview pertains primarily to an impleadment application filed during the pendency of Criminal Misc. Bail Application No. 33156 of 2025, wherein the applicant sought to add the Directorate General of GST Intelligence, CGST Commissionerate Anti Evasion Ghaziabad as an opposite party, having omitted to do so earlier by mistake. The CGST counsel raised no objection, and the impleadment application was allowed on the day itself. The underlying bail application remained for further hearing; the substantive disposal direction is not specified in the source preview.

8. Deepak Goyal vs Inspector (Anti-Evasion), Cgst

Bench: Punjab-Haryana High Court
Date: 27 October 2025
Sections engaged: 132(1)(b), 16(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed a regular bail application (CRM-M-49042-2025) under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in a complaint case filed by the CGST Commissionerate, Ludhiana. The allegations stated that two firms — M/s New Vasan Electric Company and M/s Shiv Enterprises — were involved in availing and passing of Input Tax Credit on the strength of invoices issued by suppliers whose GST registrations had been cancelled suo motu, with the petitioner said to be connected to these entities. The final disposal direction is not specified in the source preview.

9. Deepak Garg vs The Union Of India And 2 Ors

Bench: Gauhati High Court
Date: 8 September 2025
Sections engaged: 132(1)(b), 35(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed a bail application (Bail Appln./2836/2025) under Section 483 of the BNSS, 2023 before the Gauhati High Court, having been detained since 20 August 2025 in connection with a DGGI case registered by the Guwahati Zonal Unit of the Directorate General of Goods and Services Tax Intelligence. The respondents included the Additional Director General of Goods and Service Tax Intelligence and the Senior Intelligence Officer of the DGGI Guwahati Zonal Unit. The source preview records the filing and the parties; the substantive disposal direction is not specified in the available text.

10. Page No.# 1/17 vs The State Of Assam And 2 Ors

Bench: Gauhati High Court
Date: 25 June 2025
Sections engaged: 132(1)(b), 35(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The underlying petitioner identified in the source text is Varun Goyal S/o Narendra Kumar Goyal, resident of Kumarpara, Guwahati, who filed an application (Crl.Pet./699/2025) under Section 528 of the BNSS, 2023 before the Gauhati High Court seeking to set aside and quash a complaint dated 10 June 2025, the Arrest Memo dated 10 June 2025, the Grounds of Arrest dated 10 June 2025, and the Authorization to arrest dated 10 June 2025 — all issued in connection with proceedings before the Commissioner and Secretary, Department of Finance and Taxation, Assam. The final disposal direction is not specified in the source preview.

11. Samir Kumar Sahu vs Union Of India .... Opposite Party(S)

Bench: Orissa High Court
Date: 30 May 2025
Sections engaged: 132(1)(b), 132(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two bail petitions — BLAPL No. 3155 of 2025 (Samir Kumar Sahu) and BLAPL No. 3113 of 2025 (Anala Kumar Rao @ A. Kumar Rao) — were taken up together before the Orissa High Court at Cuttack arising from 2(c) CC Case No. 06 of 2025, registered pursuant to F. No. DGGI/INTL/1188/2024 dated 15 January 2025, pending before the learned S.D.J.M., Bhubaneswar. The case concerns allegations under Sections 132(1)(b) and 132(5) of the CGST Act, 2017 (as well as other sub-sections per the source), against M/s R— (name truncated in preview); both matters were heard through a hybrid arrangement and the disposal direction is not specified in the source preview.

12. Krishnamohan Vishvkarama vs Uoi Min. Of Finance Revenue Directorate

Bench: Allahabad High Court
Date: 9 April 2025
Sections engaged: 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed his first bail application (Criminal Misc. Bail Application No. 1316 of 2025) at the Lucknow Bench of the Allahabad High Court in connection with Complaint Case No. 2553 of 2025, DGGI Case No. DGGI/INV/GST/3169/2024-GR-H, P.S. DGGI, District Lucknow. The complaint, filed under Sections 210 and 223(1)(a) of the BNSS, 2023, alleged that the applicant was the mastermind behind a nexus of fake firms created to pass on fraudulent Input Tax Credit to various recipients; simultaneous searches were said to have unearthed documents indicating complicity in the creation of these fake firms, and the complaint identified the applicant as the main person responsible for filing returns under the Act. The final disposal direction is not specified in the source preview.

Patterns across these 12 rulings

Fake-invoice / fraudulent ITC as the dominant allegation. Across the cases where prosecution facts are disclosed in the source preview — including cases 3, 4, 8, and 12 — the central allegation is consistently the availing or passing on of Input Tax Credit through fictitious or inflated invoices, with no underlying supply of goods or services. This is precisely the conduct targeted by Section 132(1)(b) of the CGST Act.
DGGI as the primary prosecuting authority. In the large majority of these matters, the respondent or complainant is the Directorate General of GST Intelligence (DGGI) — whether the Chandigarh, Guwahati, Raipur, Lucknow, or Meerut Zonal Units — reflecting DGGI's central role in detecting and prosecuting large-scale GST fraud across India.
Bail applications filed under BNSS Section 483 / 528. All twelve proceedings are bail or quashing applications, filed under Section 483 or Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), confirming that the transition from the Code of Criminal Procedure to the BNSS regime is now standard in GST criminal proceedings across multiple High Courts.
Section 132(5) co-invoked in cognizable / non-bailable matters. In cases 2 and 11, Section 132(5) is invoked alongside Section 132(1)(b), signalling that the alleged amounts crossed the threshold that renders the offence cognizable and non-bailable — a feature that shapes the bail calculus significantly. Cases 5 and 6 note in their previews that the maximum punishment prescribed is imprisonment up to five years, consistent with higher-bracket allegations.
Outcome directions uniformly absent in the source corpus. All twelve orders in this corpus carry "Outcome not specified in source" — a structural feature of interim or procedural orders (bail hearings, impleadment applications, quashing petitions at early stages) rather than final merits-based decisions. Researchers seeking final disposal directions should access the complete judgment text from official court portals.

How to use this compilation

This index is designed as a first-pass research tool for identifying relevant High Court orders in the CGST Section 132(1)(b) bail-application space. Each entry provides the authoritative identity fields — bench, date, sections, and outcome direction — drawn from structured metadata, together with a brief procedural summary grounded in the available text preview. Because all twelve orders are bail or quashing applications at intermediate stages, researchers should treat the absence of an outcome direction as a prompt to retrieve the full order from indiankanoon.org or the relevant court's official e-courts portal, where the complete reasoning and any final disposal direction will be available.

When using these cases in submissions or research memoranda, always verify that the order has not been subsequently stayed, reversed, or superseded by a higher court. Bail orders in particular are frequently subject to cancellation applications or appeals; a grant of bail recorded in a High Court order may have been challenged by the investigating agency before the Supreme Court. Similarly, check whether the underlying prosecution has progressed to trial, been compounded under Section 74 or 138 of the CGST Act, or been otherwise settled, as these developments affect the precedential weight of the bail order.

Finally, note that CBIC and DGGI issue instructions, standard operating procedures, and prosecution guidelines that frame the enforcement context within which these orders are passed. Checking parallel CBIC circulars and DGGI prosecution policy documents alongside the case law will give researchers a more complete picture of the legal and administrative framework governing Section 132(1)(b) prosecutions.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 132(1)(b) CGST: 12 High Court Bail Rulings on Fake ITC (2025–2026)