This compilation indexes twelve High Court orders — spanning the Allahabad, Chhattisgarh, Punjab-Haryana, Gauhati, and Orissa High Courts — involving bail applications, habeas corpus petitions, and related criminal proceedings arising from alleged offences under Section 132(1)(b) of the Central Goods and Services Tax Act, 2017 (CGST Act). The rulings cover the period from March 2025 to June 2026 and are relevant to GST litigation practitioners, in-house legal and compliance teams, and tax researchers tracking enforcement trends in fake-invoice and fraudulent ITC cases.

Disclaimer: This page is a structured research index compiled from publicly available court orders. It is not legal advice, tax advice, or a recommendation of any course of action. Readers must verify all rulings against the original judgments and assess whether any subsequent stay, reversal, or appellate order has been passed.

The statutory framework in one paragraph

Section 132(1)(b) of the Central Goods and Services Tax Act, 2017 creates a criminal offence for any person who fraudulently avails or utilises input tax credit (ITC) without any invoice or bill, or avails ITC in excess of the ITC available to him on account of any invoice or bill, where the amount involved exceeds the threshold prescribed under the provision. The offence is cognisable and non-bailable where the amount of tax evaded or ITC wrongly availed or utilised exceeds five crore rupees, and carries a maximum punishment of imprisonment up to five years along with a fine, as indicated across the source orders in this compilation. The provision is frequently invoked by the Directorate General of GST Intelligence (DGGI) and CGST Commissionerates in enforcement actions involving networks of fake firms and fictitious invoices.

The 12 rulings

1. Mohd. Akib vs Union Of India And 2 Others

Bench: Allahabad High Court
Date: 8 June 2026
Sections engaged: 132(1), 132(1)(b), 132(3), 35, 61(2), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was filed as a Habeas Corpus Writ Petition (No. 683 of 2026) before the Allahabad High Court, with the order reserved on 29.05.2026 and delivered on 08.06.2026. Per the source preview, the petitioner arrived at the DGGI Office, Meerut Zonal Unit on 24.03.2026 for recording of his statement and was arrested on 25.03.2026 vide an arrest memo prepared by an Intelligence Officer at the Office of the Principal Commissioner, CGST, DGGI, Meerut Zonal Unit; the writ petition challenges the legality of that arrest.

2. 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 a First Bail Application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) before the High Court of Chhattisgarh at Bilaspur (MCRC No. 1519 of 2026), having been arrested in connection with Crime No. AD2212250057378B dated 20.12.2025, File No. DGGI/INV/GST/2955/2025-GR.VI, by DGGI Zonal Unit, Raipur. The prosecution's case, per the source preview, is that the applicant committed an offence of fraudulently availing 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 multiple entities including M/s Mahalaxmi Enterprises, M/s Prem Enterprises, and M/s Shri Exim.

3. 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 petition (CRM-M No. 69856 of 2025) was filed before the Punjab and Haryana High Court seeking regular bail in complaint case bearing COMA No. 518 of 2025, District Faridabad, dated 05.07.2025. Per the source preview, the complaint was registered on the statement of the Superintendent, CGST Commissionerate, Faridabad, with the allegation that the petitioner and one Sanket Mittal were involved in the issuance of fake invoices so as to avail and pass on ineligible input tax credit without actual supply of goods or services.

4. 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: This bail application (Criminal Misc. No. M-38179 of 2025) was reserved on 16.10.2025 and pronounced on 15.12.2025 before the Punjab and Haryana High Court. Per the source preview, the case was registered as Case No. INT/7-2005-Group-E, O/o ADG-DGGI-ZU-Chandigarh, and the petitioner was taken into custody on 28.05.2025; the source preview further notes that the maximum punishment prescribed for the offence is imprisonment up to five years and that investigation in the case was already complete at the time of the hearing.

5. 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: This bail application (Criminal Misc. No. M-47385 of 2025) was reserved on 12.11.2025 and pronounced on 15.12.2025 before the Punjab and Haryana High Court. Per the source preview, the matter arises from the same case registration as Case No. INT/7-2005-Group-E, O/o ADG-DGGI-ZU-Chandigarh, with the petitioner having been taken into custody on 28.05.2025 and seeking bail; the source preview notes that investigation in the case was already complete and that the maximum punishment prescribed for the offence is imprisonment up to five years.

6. 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: This matter (Criminal Misc. Bail Application No. 33156 of 2025, Neutral Citation No. 2025:AHC:194461) came up before the Allahabad High Court on an impleadment application filed alongside the bail application. Per the source preview, the applicant's counsel submitted that due to a mistake, the Directorate General of GST Intelligence, CGST Commissionerate Anti Evasion, Ghaziabad had not been impleaded as a party; CGST counsel raised no objection, and the impleadment application was allowed, permitting the applicant to implead the Directorate General of GST Intelligence, CGST Commissionerate as an opposite party.

7. 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 petition (CRM-M-49042-2025) was filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 before the Punjab and Haryana High Court seeking regular bail in a complaint case filed by CGST Commissionerate, Ludhiana. Per the source preview, during investigation conducted by the Anti-Evasion Branch, CGST Commissionerate, Ludhiana, it was found that two firms — M/s New Vasan Electric Company and M/s Shiv Enterprises — were involved in availing and passing of ITC on the strength of invoices issued by suppliers whose GST registrations had been cancelled suo motu.

8. 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: This application (Bail Appln./2836/2025) was filed under Section 483 of BNSS, 2023 before the Gauhati High Court by the petitioner, who had been detained since 20.08.2025 in connection with a DGGI case (Case No. DGGI/INV/C— per source preview). The respondents are the Union of India represented by the Directorate General of Goods and Services Tax Intelligence, Guwahati Zonal Unit, along with the Additional Director General and the Senior Intelligence Officer of that unit.

9. 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: This application (Crl.Pet./699/2025, citation 2025:GAU-AS:8597) was filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 before the Gauhati High Court seeking to set aside and quash the complaint dated 10.06.2025, the Arrest Memo dated 10.06.2025, the Grounds of Arrest dated 10.06.2025, and the Authorization to Arrest dated 10.06.2025. Per the source preview, the actual petitioner named in the body of the order is Varun Goyal, S/o Narendra Kumar Goyal, and the respondents include the Commissioner and Secretary, Department of Finance and Taxation, Assam, as well as the Principal Commissioner and Assistant Commissioner of State Tax, GST Intelligence and Enforcement Cell; the case title in CASE_FACTS reflects a document artifact (page number) rather than the petitioner's name.

10. 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. Per the source preview, the petitions arise from 2(c) CC Case No. 06 of 2025, registered pursuant to F. No. DGGI/INTL/1188/2024 dated 15.01.2025, pending before the learned S.D.J.M., Bhubaneswar, and the case concerns allegations against an entity (name truncated in preview) under various provisions of the CGST Act, 2017.

11. 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: This is a first bail application (Criminal Misc. Bail Application No. 1316 of 2025, Neutral Citation No. 2025:AHC-LKO:20055) filed before the Allahabad High Court, Lucknow Bench, in respect of Complaint Case No. 2553 of 2025, DGGI Case No. DGGI/INV/GST/3169/2024-GR-H, P.S. DGGI, District Lucknow. Per the source preview, the applicant is alleged to be a mastermind who created a nexus of fake firms to pass on fraudulent ITC to various recipients; a simultaneous search was said to have unearthed documents indicating the applicant's complicity, and it is stated in the complaint that the applicant is the main person responsible for filing returns under the Act.

12. Pritam Sovasaria vs The Union Of India And Ors

Bench: Gauhati High Court
Date: 18 March 2025
Sections engaged: 132(1)(b), 132(1)(c), 16(2)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: This bail application (Bail Appln./477/2025) was filed before the Gauhati High Court by the proprietor of M/s P.S. Enterprise, with the respondents being the Union of India represented by the Director General of Goods and Services Tax Intelligence, Guwahati Zonal Unit, along with the Director General and an Intelligence Officer of that unit. Per the source preview, the standing counsel for GST appeared on behalf of the respondents; substantive ground details beyond the bail application context are not further elaborated in the available source preview.

Patterns across these 12 rulings

Uniform enforcement agency: All twelve matters were initiated by the Directorate General of GST Intelligence (DGGI) or CGST Commissionerate units across different zonal jurisdictions, reflecting the central role of these agencies in prosecuting fake-invoice ITC fraud under the CGST Act.
Bail and arrest challenges as the primary procedural vehicle: Across the compilation, the predominant procedural posture is that of the accused filing bail applications under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, or in one instance a habeas corpus writ petition, indicating that the immediate legal contest in these matters focuses on personal liberty rather than the underlying tax demand.
Fake-invoice networks as the recurring factual allegation: In the cases where the source preview provides sufficient detail — including Cases 2, 3, 7, and 11 — the prosecution's central allegation is the creation or use of networks of fictitious firms to generate fake invoices and fraudulently pass on ITC, without actual supply of goods or services.
Multi-High Court geography: The twelve orders span five High Courts (Allahabad, Chhattisgarh, Punjab-Haryana, Gauhati, and Orissa), demonstrating that enforcement of Section 132(1)(b) is geographically distributed and not concentrated in any single jurisdiction.
Incomplete outcome data across the compilation: None of the twelve rulings have an outcome direction specified in the source data, which may reflect that these are interlocutory orders on bail or impleadment applications rather than final disposals, or that the final operative portion of the orders was not captured in the available text preview. Researchers should obtain the full text of each order to determine the operative directions.

How to use this compilation

This compilation is intended as a starting point for legal and tax research, not a substitute for reading the full text of each judgment. Each entry in this index provides only the information available in the structured source data and text preview; material facts, operative holdings, conditions imposed, and any subsequent developments will only be visible in the complete order as published on the relevant High Court portal or indiankanoon.org. Researchers are strongly advised to retrieve the full text using the neutral citation numbers referenced in the source previews before relying on any ruling for litigation, compliance, or advisory purposes.

Before drawing conclusions from any ruling listed here, practitioners should verify whether the order has been stayed, reversed, or modified by a coordinate bench or appellate court, and whether any special leave petition has been filed before the Supreme Court. Bail orders in particular are interlocutory in nature and do not reflect a final adjudication on the merits of the underlying prosecution. Readers should also check whether any compounding or settlement under the CGST Act has occurred subsequent to the order date.

Finally, for a complete picture of the enforcement landscape under Section 132(1)(b), researchers should cross-reference the rulings in this index with CBIC circulars and instructions on prosecution guidelines, any DGGI standing orders on arrest procedures, and the judicial interpretation of cognisability and bail-eligibility thresholds as they have evolved through Supreme Court and High Court decisions in the period covered by this compilation.

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.

CGST Section 132(1)(b): 12 High Court Bail & Arrest Rulings (2025–2026)