This compilation indexes 12 judicial proceedings — spanning the Allahabad High Court, Chhattisgarh High Court, Punjab-Haryana High Court, and the Income Tax Appellate Tribunal (Patna Bench) — in which Section 132(1) was cited as the operative penal or search-and-seizure provision. The rulings were decided between October 2025 and May 2026. The majority arise from bail applications filed by accused persons in CGST prosecution matters involving allegations of fraudulent Input Tax Credit (ITC) availment or fake invoicing; one proceeding originates before the ITAT in an income-tax search context. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers tracking judicial trends in Section 132(1) matters.

Research index only. This page compiles publicly available court and tribunal orders for academic and professional research purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any kind. Always verify against the full text of the judgment and consult qualified counsel before acting.

The statutory framework in one paragraph

Section 132(1) of the Central Goods and Services Tax Act, 2017 sets out the offences for which a person may be prosecuted under that Act, including (among others) supply of goods or services without invoice, issuance of invoices without actual supply, availment or utilisation of input tax credit using fraudulent means, and collection of tax but failure to deposit the same with the Government within specified timelines. The provision prescribes the punishments — including imprisonment and fine — for these offences, with the severity of punishment calibrated to the quantum of tax evaded. A cognate provision bearing the same section number exists in the Income Tax Act, 1961, where Section 132(1) governs the conditions under which the authorised officer may conduct search and seizure operations. Both provisions appear across the cases in this compilation depending on the forum and the specific proceeding.

The 12 rulings

1. Ashok Kumar Paswan @ Chootu vs State Of U.P.

Bench: Allahabad High Court
Date: 8 May 2026
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The application was filed as Criminal Misc. Bail Application No. 11891 of 2026 before the Allahabad High Court, seeking enlargement on bail in Case Crime No. 543 of 2025. The bail application of the applicant before the court below had been rejected by the Additional Sessions Judge-1st, Auraiya, and the applicant was stated to have been in custody since 23.02.2026; the full disposal of the bail application is not captured in the source preview.

2. Anil Singh vs Union Of India

Bench: Chattisgarh High Court
Date: 1 April 2026
Sections engaged: 132(1), 69(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed a First Bail Application (MCRC No. 1482 of 2026) under Section 483 of the Bharatiya Nagarik Suraksha Sanhita seeking regular bail; he had been arrested in connection with Crime No. AD220126005154U, Police Station DGGI, Raipur. The prosecution alleged that the applicant, acting as operator/director of two firms — M/s Sonam Sales and M/s Yuvraj Trading Company — facilitated "bogus billing" linked to an investigation that originated from M/s Ramdoot Enterprises (Mirzapur, UP), which was found to be procuring goods from non-existent or suspended firms.

3. Vikram Mandhani vs Union Of India

Bench: Chattisgarh High Court
Date: 17 March 2026
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed a First Bail Application (MCRC No. 1975 of 2026) under Section 483 of the BNSS before the Chhattisgarh High Court; the arrest arose from Crime No. AD2212250057378B dated 20.12.2025, registered by DGGI Zonal Unit Raipur. The prosecution's case, per the source preview, was that the applicant committed an offence by issuing fake invoices amounting to ₹8,57,15,507/- and fraudulently availing Input Tax Credit, with the investigation having been conducted into M/s Prem Enterprises, a firm registered for the trade of steel goods.

4. Jashanpal Singh vs Union Of India

Bench: Punjab-Haryana High Court
Date: 2 February 2026
Sections engaged: 132(1), 2(11), 7(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The Punjab-Haryana High Court disposed of two connected petitions — CRM-M-53422-2025 (Jashanpal Singh) and CRM-M-62114-2025 (Preet Pal Garg) — by a common order, as both arose out of the same complaint and involved common questions of fact and law. The judgment was reserved on 19.01.2026 and pronounced on 02.02.2026; the full operative findings are not reproduced in the source preview.

5. Rattan Kumar Garg vs Directorate General Of GST

Bench: Punjab-Haryana High Court
Date: 12 January 2026
Sections engaged: 132(1), 132(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner filed a first petition under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 for grant of regular bail (CRM-M-56606 of 2025) during the pendency of trial/investigation in an offence under Sections 132(1)(B) and 132(1)(C) read with 132(5) of the CGST Act, 2017. The prosecution's allegations, per the source preview, centred on M/s Steel N Steel (GSTIN: 03AGOPG9408N2ZZ), a proprietary firm based in SAS Nagar, Punjab, alleged to have been engaged in availing and passing on of fraudulent ITC.

6. Tushal Raheja vs Union Of India Through Intelligence

Bench: Allahabad High Court
Date: 24 November 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 40185 of 2025) was filed before the Allahabad High Court seeking release in Case Crime No. DGGI/INV/GST/1498/2025, Police Station DGGI, Regional Unit-Kanpur. Per the source preview, the allegation was that the applicant along with others committed GST fraud of approximately six crores; counsel for the applicant submitted that the alleged offence carries a maximum punishment of five years, the offence is triable by a Magistrate, and the applicant had been in custody since 12.09.2025 — more than two months at the time of hearing.

7. Deepak Murjhani vs Union Of India

Bench: Allahabad High Court
Date: 11 November 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 37416 of 2025) was filed before the Allahabad High Court seeking release in Case No. 2118 of 2023 arising out of Criminal Complaint No. 1534 of 2023-24, registered at Police Station DGGI, Ghaziabad Unit, District Meerut, during the pendency of trial. Per the source preview, the prosecution alleged that the applicant, by forming fake firms, availed input tax credit of approximately Rs. Three Crores and thereafter passed the same; counsel for the applicant denied the allegations and argued that all offences are triable by a Magistrate with a maximum punishment of five years.

8. Arun Garg vs State Of Haryana

Bench: Punjab-Haryana High Court
Date: 3 November 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRM-M-25342-2025) was filed under Section 483 BNSS seeking bail in case COMA No. 247 of 2025 titled "CGST Faridabad Vs. Arun Garg." Per the source preview, the prosecution alleged that the petitioner ran a syndicate of 9 taxpayer firms with the criminal intention of availing and passing fraudulent ITC generated through those firms by issuing goods-less invoices, with a taxable value of Rs. 1,30,33,91,023/- and fraudulent/fake ITC of Rs. 23,66,02,499/- said to have been passed on to various taxpayers.

9. Sagar Singhal vs Union Of India

Bench: Allahabad High Court
Date: 28 October 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 36786 of 2025) was filed before the Allahabad High Court seeking release in Case No. 790 of 2025, registered at DGGI, Meerut. Per the source preview, the allegation was that the applicant, as Director of three Private Limited Companies, availed input tax credit of more than Rs. 100 Crores and subsequently passed on the same on the basis of fake documents; counsel for the applicant denied the allegations and submitted that all offences are triable by a Magistrate with a maximum punishment of five years.

10. Dhiraj Nath Gupta vs Union Of India

Bench: Allahabad High Court
Date: 16 October 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 32145 of 2025) was filed before the Allahabad High Court seeking release in Case No. 3019 of 2024, Police Station DGGI Regional Unit, District Ghaziabad, during the pendency of trial. Per the source preview, the prosecution alleged that the applicant, by forming a number of shell companies, availed input tax credit of about Rs. 32 Crores and passed the same; counsel submitted that the investigation had been completed and a complaint had already been filed, removing any ground for continued detention.

11. Murlidhar Prasad,Patna vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Patna
Date: 14 October 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is the sole Income Tax Act matter in this compilation, filed before the Income Tax Appellate Tribunal, Patna Bench. The source preview indicates a consolidated set of appeals including ITA Nos. 272, 273, 274, 275, 276 and 278/PAT/2023 filed by Murlidhar Prasad (PAN: AEKPP 1361 D) against ACIT, Central Circle-1, Patna, covering multiple assessment years; the preview also reflects several other consolidated matters in the same batch. The full substantive findings of the Tribunal are not reproduced in the source preview.

12. Ayush Agarwal vs Union Of India

Bench: Allahabad High Court
Date: 14 October 2025
Sections engaged: 132(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 34005 of 2025) was filed before the Allahabad High Court seeking release in Case No. 790 of 2025, Police Station DGGI, Meerut, District Meerut, during the pendency of trial. Per the source preview, the prosecution alleged that the applicant, a Chartered Accountant, facilitated co-accused Sagar Singhal by enabling the availment and subsequent passing on of input tax credit in excess of Rs. 100 crores on the basis of fake documents; counsel for the applicant denied the allegations and submitted that all offences are triable by a Magistrate with a maximum punishment of five years.

Patterns across these 12 rulings

Bail applications dominate the docket. Eleven of the twelve cases in this compilation are criminal bail proceedings — not civil tax appeals — arising from arrests made by DGGI or CGST authorities under the penal provisions of Section 132(1) of the CGST Act. The only income-tax proceeding is case 11 (ITAT Patna), which involves a search matter under the Income Tax Act.
Fake invoicing and fraudulent ITC are the common prosecution allegation. Across the High Court matters, the prosecution's case in each instance, as recorded in the source previews, centres on allegations of issuance of fake or goods-less invoices and the availment or passing-on of fraudulent Input Tax Credit — indicating a consistent enforcement focus by DGGI and CGST authorities on ITC fraud networks.
Scale of alleged fraud varies significantly. The quantum of alleged fraudulent ITC ranges from approximately Rs. 3 Crores (case 7) to over Rs. 100 Crores (cases 9 and 12), with case 8 disclosing an alleged taxable value of over Rs. 130 Crores across nine firms. This variation suggests that Section 132(1) prosecutions are initiated across a wide spectrum of alleged fraud values.
Recurring procedural arguments in bail matters. Per the source previews, applicants across multiple cases advanced similar bail arguments: that the alleged offences carry a maximum punishment of five years, that they are triable by a Magistrate (not a Sessions Court), and that the investigation had already concluded with a complaint filed — making continued detention unnecessary. These arguments appear in cases 6, 7, 9, 10, and 12.
Geographic concentration in certain High Courts. The Allahabad High Court accounts for the largest share of matters in this compilation (cases 1, 6, 7, 9, 10, 11, and 12), followed by the Punjab-Haryana High Court (cases 4, 5, and 8) and the Chhattisgarh High Court (cases 2 and 3), reflecting the geographic spread of DGGI enforcement activity covered in the source corpus for this period.

How to use this compilation

This index is a starting point for legal research, not a substitute for reading the full judgment text. Each entry above records only what is available in the structured source preview; in all twelve of these cases the outcome field records "Outcome not specified in source," which means the operative direction of the court or tribunal's order is not confirmed in the available data. Researchers must retrieve the complete judgment — using the neutral citation numbers referenced in the source previews where available, or through indiankanoon.org and official court portals — before drawing any conclusions about the legal position in any individual case.

Before relying on any ruling for a legal position, verify whether the order has been stayed, reversed on appeal, or distinguished in a subsequent judgment. Bail orders in criminal matters are interlocutory in nature and do not constitute final determinations of guilt or of the legal questions arising under Section 132(1). Additionally, researchers should check whether any relevant CBDT instructions, CBIC circulars, or departmental guidelines have been issued that bear on the substantive interpretation of Section 132(1) in the context under examination.

Where a matter involves both CGST Act Section 132(1) and Income Tax Act Section 132(1), take care to identify the correct statutory context, as the provisions are distinct in scope, procedure, and consequence. The cases in this compilation span both statutes; case 11 (ITAT Patna) is an income-tax search matter, while all other cases arise under the CGST Act. Cross-statute comparisons require caution and should be grounded in the specific text and judicial interpretation applicable to each regime.

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) CGST Bail Applications: 12 High Court & ITAT Rulings (2025–2026)