1. INTRODUCTION
Online gaming has garnered a lot of media attention in the
recent past, owing to high-pegged demands of approximately INR 1.12
Lakh Crores (Indian Rupees One Point Twelve Lakh Crores) that has
been raised under 71 (seventy-one) show cause notices issued by the
Indian tax authorities (“Tax Authorities”), under the
Goods and Services Tax Laws1 (“GST Laws”), for the
period July 2017 - September 2023.
The said demands have been raised in the backdrop of two major
events namely, (a) the GST Council's recommendation and
subsequent amendments to the GST Laws2 to levy Goods and Services
Tax (“GST”), at the rate of 28% (twenty-eight per
cent), on the deposit amount paid by the users in online games, and
(b) the Supreme Court (“SC”) order3 staying the
operation of the judgment passed by the Karnataka High Court4
(“Karnataka HC”) in the case of Gameskraft Technologies
(“Gameskraft”). The main allegations raised on behalf
of the Tax Authorities, before the SC
