In Brief
The Supreme Court addressed whether a lottery ticket agent was liable to pay tax under the Kerala Tax on Paper Lotteries Act, 2005. The respondent firm acted as an agent of Karnataka's lottery sole selling agent and purchased bulk lottery tickets on behalf of members without physically handling them in Kerala. The Court held that the term 'promoter' under Section 2(1) of the Act—meaning a government or a person appointed by government to sell tickets on its behalf—is exhaustive and cannot be expanded. Since the respondent's appointment expressly barred it from operating outside Karnataka, it was not appointed to sell tickets in Kerala on the government's behalf. Therefore, it did not qualify as a 'promoter' and was not liable to tax or registration. The Court affirmed strict construction principles in taxing statutes, rejecting any unreasonable extensions.
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