This compilation indexes twelve High Court rulings — spanning April 2024 to April 2026 — in which Section 132(1)(c) of the Central Goods and Services Tax Act, 2017 (CGST Act) was engaged. The matters covered include regular bail applications, anticipatory bail petitions, habeas corpus writ petitions, and recall applications arising from DGGI-initiated prosecutions. The compilation is intended for GST litigation researchers, in-house compliance teams, and law firm associates tracking the judicial treatment of bail and pre-trial liberty questions under the CGST penal framework.

Research index only. This page is a structured case-law reference tool and does not constitute legal advice. Readers must consult the full text of each judgment and verify current status before placing reliance on any ruling.

The statutory framework in one paragraph

Section 132(1)(c) of the Central Goods and Services Tax Act, 2017 creates a cognisable and non-bailable offence for any person who avails input tax credit using fraudulent means, false invoices, or invoices issued in respect of a supply that has not actually taken place. The provision prescribes graduated punishment tied to the quantum of tax evaded: where the amount involved exceeds five crore rupees, the offence attracts imprisonment for a term which may extend to five years along with a fine. Because the offence is non-bailable, arrested persons must approach a competent court — typically the Special Court or, on revision/application, a High Court — for the grant of bail, which explains the high volume of Section 132(1)(c) bail litigation indexed below.

The 12 rulings

1. Sandeep Singhal vs Directorate General Of GST

Bench: Allahabad High Court
Date: 6 April 2026
Sections engaged: 132(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as a Habeas Corpus Writ Petition (No. 257 of 2026) before the Allahabad High Court, seeking a writ in the nature of certiorari to set aside an order dated 15.01.2026 passed by the Remand Magistrate/ACJM Court No. 07, Meerut, in Case No. 1629/2025, under the CGST Act, 2017, and all consequential proceedings thereof. The petition was heard by a Division Bench and was at an interim hearing stage as per the source preview, with the court having passed an interim order on 31.03.2026.

2. Saurabh Bansal vs Directorate General Of GST, Ludhiana

Bench: Punjab-Haryana High Court
Date: 24 February 2026
Sections engaged: 132(1)(c), 20
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRM-M-68325-2025) was filed for grant of regular bail to the petitioner in a case arising out of complaint No. 58610 dated 15.11.2025, pending before the Judicial Magistrate 1st Class. The allegations against the petitioner were that he had availed input tax credit amounting to Rs. 26.19 crores by producing fake invoices issued by non-existent or bogus firms without actual supply of any underlying goods whatsoever.

3. Shivam Gupta vs State Of Punjab And Others

Bench: Punjab-Haryana High Court
Date: 23 February 2026
Sections engaged: 132(1)(c), 132(1)(i), 67(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter involved two connected petitions (CRM-M-503-2026 and CRM-M-2739-2026) heard together, with judgments reserved on 13.02.2026 and pronounced in full on 23.02.2026. The source preview indicates the proceedings were substantive bail applications filed before the Punjab and Haryana High Court against the State of Punjab and other respondents; the full reasoning of the order is not available in the source preview.

4. Jitender Saharan vs Senior Intelligence Office

Bench: Punjab-Haryana High Court
Date: 14 January 2026
Sections engaged: 132(1)(c), 132(5), 20(xv)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRM-M No. 61814 of 2025) was filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking anticipatory bail in case No. DGGI/INT/625/2025-GR-D filed by the Directorate General of GST Intelligence, Chandigarh Zonal Unit. The allegations, as per the source preview, were that four GST-registered entities — M/s Pukhraj Packaging Solutions, M/s Sun Industries, M/s Pukhraj Packaging Solutions Private Limited, and M/s Pukhraj Packaging Solutions — had availed, utilised, and passed on ineligible input tax credit.

5. Dipanshu Anand vs Principal Commissioner, Central GST

Bench: Punjab-Haryana High Court
Date: 27 October 2025
Sections engaged: 132(1)(c), 74(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRM-M-44890-2025) was filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 for grant of regular bail arising out of complaint No. GEXCOM/AE/INV/570/2025-AE, Office of PR Commissioner-CGST-Ludhiana. As per the source preview, investigation conducted by DGGI, Regional Unit, Amritsar revealed that M/s Gauri Shankar Metal Industries, a partnership concern of the petitioner, and M/s Shivansh Enterprises, a sole proprietary concern of the petitioner, were allegedly engaged in availment of fraudulent input tax credit.

6. Narender Kumar vs Directorate General Of GST

Bench: Delhi High Court
Date: 8 October 2025
Sections engaged: 132(1)(c), 41A, 35
Outcome: Outcome not specified in source
Procedural / substantive ground: A regular bail application (BAIL APPLN. 3065/2025) was filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita read with Section 439 of the Code of Criminal Procedure in File No. DGGI/INT/14/2024-Gr I. The applicant submitted that he was arrested on 04.06.2025 from his residence without any prior service of summons or notice to join the investigation, and that the arrest memo and grounds of arrest were provided after an inordinate delay of nearly 14 hours, which was asserted to be in violation of principles of natural justice.

7. Manoj Kumar Garg vs Union Of India

Bench: Allahabad High Court
Date: 10 September 2025
Sections engaged: 132(1)(c), 73
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (Criminal Misc. Bail Application No. 29837 of 2025) sought release on bail in Case No. 88 of 2020, filed by the Additional Directorate General, DGCI, GST Ghaziabad Regional Unit, Meerut Zonal Unit, Meerut, during pendency of trial in the court below. The source preview indicates this was technically the third bail application filed on behalf of the applicant; the earlier two applications had not been dismissed on merits — the first was dismissed as not pressed vide order dated 2.1.2023, and the second was dismissed on 4.7.2025 on a separate ground.

8. Directorate General Of GST vs Rakesh Kumar Goyal

Bench: Delhi High Court
Date: 27 June 2025
Sections engaged: 132(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRL.M.C. 631/2021) under Section 482 of the Code of Criminal Procedure, 1973 was filed by the Directorate General of GST Intelligence to seek recall of an order dated 23.12.2020 vide which bail had been granted to the respondent/Rakesh Kumar Goyal. The complaint against the respondent related to offences under Section 132(1)(c) of the CGST Act, 2017 on account of evasion of CGST running into crores of rupees, with DGGI having developed intelligence that multiple entities — including M/s Aastha Apparels Pvt. Ltd., M/s JBB Apparels Pvt. Ltd., M/s JBN Apparels Pvt. Ltd., and M/s Nautilus Metal Craft Pvt. Ltd. — were engaged in fraudulent availment of input tax credit on invoices of non-existing and fictitious firms.

9. 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: The matter was filed as Bail Application No. 477/2025 before the Gauhati High Court, with the petitioner described as the proprietor of M/s P.S. Enterprise. The application was heard before the Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh) and the respondents included the Director General of Goods and Services Tax Intelligence, Guwahati Zonal Unit; the substantive reasoning of the order is not available in the source preview.

10. Furkan Malik vs Directorate General Of Goods And

Bench: Allahabad High Court
Date: 31 August 2024
Sections engaged: 132(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (Application U/S 482 No. 27821 of 2024) was moved under Section 482 Cr.P.C. by the accused applicant, who was aggrieved by condition no. 4 contained in the bail order dated 9.12.2020 passed by the Special Chief Judicial Magistrate, Meerut in Case No. 80/2020, where bail had been granted in a matter involving alleged tax evasion to a tune of Rs. 5 crore. An amendment application was also moved to correct the name of the Magistrate Court mentioned in the application and affidavit, which was allowed by the court.

11. Dipen Champaklal Shah vs State Of Gujarat

Bench: Gujarat High Court
Date: 30 April 2024
Sections engaged: 132(1)(c), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (R/Criminal Misc. Application No. 7408 of 2024) was filed under Section 439 of the Code of Criminal Procedure, 1973 for regular bail before chargesheet in connection with File No. STO-3/U-98/JMR/SEC-69/VOLT METAL IND/2023-24/O.W. NO. 17 dated 12.02.2024, registered with the State Tax Officer (3) Unit-98, Jamnagar. The applicant was the proprietor of M/s Volt Metal Industries, engaged in manufacturing and trading of brass products and metal scrap at Jamnagar; a vehicle bearing Registration No. KA-02-AH-7875 carrying goods belonging to the applicant was intercepted by the State Tax Officer, Jamnagar on 08.04.2022.

12. Smit Dipen Shah vs State Of Gujarat

Bench: Gujarat High Court
Date: 3 April 2024
Sections engaged: 132(1)(c), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (R/Criminal Misc. Application No. 5864 of 2024) was filed under Section 439 of the Code of Criminal Procedure, 1973 for regular bail before chargesheet in connection with File No. 142 dated 02.02.2024, registered with the State Tax Officer (3), Enforcement, Division-11, Junagadh. The applicant was the proprietor of M/s Liberty Products, engaged in manufacturing and trading of brass products and metal scrap at Jamnagar; a vehicle bearing Registration No. KA-51-AG-4149 carrying goods belonging to the applicant was intercepted by the State Tax Officer, Jamnagar on 09.04.2022.

Patterns across these 12 rulings

Bail and pre-trial liberty is the dominant procedural theme. Across all twelve cases, the central judicial action was a bail application (regular or anticipatory), a bail recall petition, or a habeas corpus writ petition — not an appeal against the underlying assessment or penalty. This reflects the non-bailable character of the Section 132(1)(c) offence and the consequent volume of liberty-related High Court litigation.
Fraudulent ITC availment via fake or non-existent suppliers is the recurring factual allegation. In multiple cases where the text preview contains substantive allegations — including cases 2, 4, 5, and 8 — the DGGI's complaint rested on allegations that input tax credit was availed against invoices issued by non-existent, fictitious, or bogus firms without actual underlying supply of goods or services.
DGGI zonal units are the consistent prosecuting authority. The Directorate General of GST Intelligence, operating through its regional and zonal units (Meerut, Chandigarh, Ludhiana, Amritsar, Delhi, Guwahati), appears as the initiating authority across the vast majority of these cases, reflecting DGGI's operational role as the primary investigation and prosecution arm for large-scale GST evasion.
Multiple High Courts are active in this jurisdiction. The twelve cases span five High Courts — Allahabad, Punjab-Haryana, Delhi, Gauhati, and Gujarat — indicating that Section 132(1)(c) bail litigation is not confined to a single circuit and that divergent approaches across benches may exist, making cross-court research essential for practitioners.
Procedural grounds alongside substantive allegations. At least one case (case 6 — Narender Kumar) raised procedural complaints about the manner of arrest, including alleged non-service of summons prior to arrest and delayed provision of the arrest memo and grounds of arrest, alongside the substantive CGST evasion allegation. This signals that arrest procedure compliance is a distinct litigation axis in Section 132(1)(c) matters.

How to use this compilation

This index is organised by case identity and procedural posture as extracted from source court documents. Each entry provides the bench, date, sections engaged, and a brief procedural note drawn directly from the available source preview. Because the source preview for several cases captures only the opening paragraphs of the order, the substantive reasoning and the final operative direction of the court are frequently not available here. Researchers must retrieve the full text of each judgment — via the neutral citation reference where provided, the court portal, or indiankanoon.org — before drawing any conclusions about the holding, ratio, or outcome of the case.

When conducting precedent research on Section 132(1)(c) bail matters, researchers should also verify whether the order in question has been subsequently stayed, modified, or reversed by a coordinate or superior bench. Bail orders, in particular, are frequently subject to recall applications (as illustrated by case 8 in this compilation) and interim stay orders from higher courts. Similarly, where a matter relates to an ongoing criminal complaint, the status of the trial proceedings before the Special Court should be independently verified.

Researchers should also cross-reference relevant CBIC instructions and circulars on arrest and bail policy under the CGST Act, as the Department's internal guidelines on when to arrest and when to invoke Section 132 are relevant context for understanding the policy environment within which these cases arise. Nothing in this compilation constitutes legal advice, and no entry should be read as an authoritative statement of the law applicable to any specific facts.

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)(c) CGST Act: 12 High Court Bail & Habeas Corpus Rulings (2024–2026)