₹95 Crore GST Evasion via Online Gaming Transactions: Rajasthan HC Rejects Bail to Payment Aggregator Facilitators [Read Order]

The Rajasthan High Court, Jaipur Bench, has refused to grant bail to two accused alleged to have played a key role in large-scale GST ( Goods and Services Tax ) evasion of nearly ₹95 crore through online gaming transactions routed via payment aggregators.

The Court held that the case involves serious economic offences with deep financial concerns, electronic trails, and cross-border elements, warranting a strict approach at the bail stage.

The bail applications were filed by Manoj Kumar and Jagdish, who were arrested in September 2025 in connection with offences under Sections 132(1)(i) and 132(5) of the Central Goods and Services Tax Act, 2017. The case was registered by the Directorate General of GST Intelligence (DGGI), Udaipur Regional Unit, under the Jaipur Zonal Unit.

According to the prosecution, the applicants were not direct gaming operators but acted as facilitators who helped onboard multiple private companies namely M/s Invoestr Global Pvt. Ltd., M/s Involanding Games Pvt. Ltd., and M/s Chefbiz Spices Pvt. Ltd. with various online payment aggregators. These entities allegedly received massive online gaming revenues through UPI IDs and virtual payment addresses without discharging applicable GST.

The investigation revealed that initial receipts of around ₹53.21 crore were admitted in the name of one company, while further scrutiny uncovered additional collections aggregating to over ₹342 crore routed through other entities and payment intermediaries.

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The total alleged GST evasion was ultimately quantified at approximately ₹95.77 crore, far exceeding the statutory threshold of ₹5 crore that renders the offence cognizable and non-bailable.

The accused argued that they were merely service providers who earned commission for facilitating onboarding with payment aggregators and could not be treated as “deemed suppliers” under the GST law.

They also contended that the maximum punishment prescribed under the CGST Act is five years and that the investigation concluded with the filing of the final complaint in November 2025, making continued custody unnecessary.

Opposing bail, the DGGI submitted that the accused had facilitated complex electronic transaction structures involving multiple intermediaries, cancelled GST registrations, and NIL returns despite huge financial flows. The statements recorded under Section 70 of the CGST Act allegedly contained admissions regarding exchange of company credentials for commission and onboarding of multiple entities.

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The Court noted that the case involved massive electronic evidence, multiple third-party payment intermediaries, and even foreign communication links, creating a real risk of tampering with evidence, deletion of digital records, and flight from justice if bail were granted.

The High Court bench of Justice Sameer Jain, noting the gravity of offence, observed that GST evasion on such a scale has a direct impact on the economy and cannot be equated with ordinary crimes. It further held that the accused had approached the Court with “unclean hands” by downplaying the true magnitude of evasion, which was later revised upwards during investigation.

Therefore, the Rajasthan High Court dismissed the bail applications. It clarified that its observations were limited to the bail stage and would not prejudice the merits of the case during trial.

Mr. Naqvi Sehban Najib with Mr. Jaswant Sharma Ms. Morvi Jangid Ms. Rabiya Mateen Mr. Narendra Kumar, Advocates appeared for the appellants.

Mr. Bharat Vyas, AAG assisted by Mr. Jitendra Singh Poonia, Spl. PP DGGI & Ms. Neeti Jain Bhandari; Dr. Ajay Kumar, Addl. Director DGGI; Mr. G.K. Sudhakar, Asst. Director DGGI; Mr. Santosh Kumar Meena, Sr. Intelligence Officer; Mr. Amit Sheokand, Intelligence Officer; Ms. Arti Sharma, PP and Mr. Rhishi Raj Singh Rathore, PP appeared for the respondents.

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