Gaming firms file review pleas against Supreme Court's 28% GST ruling.
Companies say GST should apply only on transfer of winnings.
Petitions challenge retrospective tax demands worth ₹1.5 lakh crore.
Major online gaming companies have approached the Supreme Court seeking a review of its May 27 judgment, which upheld the constitutional validity of the 28% goods and services tax (GST) on online gaming and rejected challenges to retrospective tax demands worth over ₹1.5 lakh crore, according to NDTV Profit.
Play Games24x7 and Junglee Games have filed review petitions before the Supreme Court, and several other online gaming companies are expected to do the same, the report said.
4 July 2026
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The petitions argue that the case involved significant legal questions and should have been referred to a larger Constitution Bench for consideration.
According to the review pleas, the Supreme Court incorrectly allowed GST to be levied on the creation of actionable claims, rather than restricting the tax to the transfer of winnings.
The petitions state that GST should apply only when winnings are transferred to players, and not at the stage when players pay an entry amount to participate in a game.
The petitions also allege that the Supreme Court misread the "sunrise clause" introduced through amendments to the GST law, which resulted in the provisions being applied retrospectively.
The gaming companies have argued that the 28% GST regime should apply only from October 2023, when the amended legal framework came into effect, and not to periods before that date.
The review petitions further argue that the judgment results in inconsistent treatment between online and offline gaming, even though both involve similar underlying activities, the report said.
Background Of The Case
The review petitions follow the Supreme Court's May 27 judgment, which upheld the 28% GST levy on online gaming and rejected challenges filed by gaming companies. The ruling effectively revived tax demands estimated at around ₹1.5 lakh crore.
The review proceedings are expected to be closely watched by the online gaming industry, as the outcome could determine whether the Supreme Court reconsiders the scope and applicability of one of the country's largest indirect tax disputes.
