I think they're referring to the marketing budget, which isn't accounted for in the development budget.
> Media analyst Arvind Bhatia estimated the game's development budget exceeded US$137 million,[7] and The Scotsman reporter Marty McLaughlin estimated that the combined development and marketing efforts exceeded GB£170 million (US$265 million), making it the most expensive video game ever made at its time
And here's wikipedia's source on the $137m
https://www.gamesindustry.biz/articles/2013-02-01-gta-v-dev-...