Debangsu Basak, J.

The petitioners have sought a declaration that, lotteries are exempt from tax under Sl. No. 6 of Schedule III read with Section 72 of the Central Goods and Service Tax Act, 2017 and Sl. No. 6 of Schedule III read with Section 72 of the State Goods and Service Tax Act, 2017.

2. Learned Senior Advocate appearing for the petitioner has submitted that, a lottery cannot come within the definition of 'goods'. Referring to (H. Anraj v. Government of Tamil Nadu, 1986 1 SCC 63) he has submitted that, the initial view of the Supreme Court was that, lottery tickets to the extent they comprise the entitlement to participate in the draw, are goods. Such view was reversed in (Sunrise Associates v. Government of NCT of Delhi, 2005 5 SCC 603). Both, the Central Goods and Services Tax Act, 2017 (CGST) and the State Goods and Services Tax Act, 2017 (SGST) define 'goods'. Such definition includes actionable claim and excludes money and securities. He has referred to Section 7 read with Schedule III Entry 6 of CGST Act, 2017 in support of his contention. He has referred to the definition of 'goods' in Article 366(12) of the Constitution. He has submitted that, 'goods' as def