Paytm’s First Games to challenge Rs 5,712 crore GST notice

The notice, received on April 28, 2025, relates to an ongoing Goods and Services Tax (GST) matter that has been under review across the online gaming industry for over 18 months.

New Delhi: Paytm’s parent company, One97 Communication Ltd (OCL), has said that its subsidiary, First Games Technology Private Limited, received a show-cause notice (SNC) from the Directorate General of GST Intelligence (DGGI).

The notice, received on April 28, 2025, relates to an ongoing Goods and Services Tax (GST) matter that has been under review across the online gaming industry for over 18 months.

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The DGGI has taken the position that GST should be levied at 28 per cent on the total entry amount, instead of the 18 per cent GST currently paid on the platform fee or revenue earned by gaming companies.

In its stock exchange filing, Paytm emphasised that this is an industry-wide issue, and that several other online gaming operators have received similar notices in the past.

This matter is currently pending before the Supreme Court, which has granted interim relief by staying further proceedings on previously issued notices after hearing writ petitions filed by multiple gaming companies.

“In line with the industry,” Paytm stated in its filing, “First Games will also be filing a writ petition challenging the SCN on legal grounds, including the retrospective application of the GST amendment dated October 1, 2023, and/or the interpretation of GST regulations prior to the amendment.”

The petition will seek interim relief in line with what has been granted to other gaming operators.
The SCN issued to First Games proposes a GST liability of Rs 5,712 crore, along with applicable interest and penalties, for the period from January 2018 to March 2023.

Paytm has clarified that this development does not impact its operations or other activities.

“First Games is considered a joint venture for group consolidation purposes under applicable accounting standards, and hence its revenues are not consolidated with OCL,” the company said.

It added that First Games contributed less than 1 per cent to its consolidated profit/loss for the financial year ended March 31, 2024. The filing also noted that the carrying value of Paytm’s investment in First Games is already nil as of March 31, 2024.

OCL’s financial exposure to First Games stands at approximately Rs 225 crore, primarily in the form of a shareholder loan (including applicable interest) as of December 31, 2024.