In Brief
The Supreme Court held that a partnership firm acting as an agent of a lottery ticket seller, but expressly restricted from selling outside Karnataka, does not qualify as a 'promoter' under the Kerala Tax on Paper Lotteries Act, 2005. The definition of 'promoter' is exhaustive and cannot be expanded through interpretation. Consequently, the respondent was not liable to pay tax under the Act or to register. The Court reaffirmed the principle that taxing statutes must be strictly construed within their letter; equitable considerations cannot extend tax liability beyond what the statute explicitly provides.
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