Wangdi, J.

By filing this Writ Petition, the Petitioner seeks to assail letter C. No.V(3)7/ST/FGSIPvtLtd/GTK/2009/ 295 dated 06-07-2012 issued by the Superintendent of Central Excise and Service Tax, Gangtok Range, Gangtok, Respondent No.3, informing the Petitioner that as per Notification No.36/2012-ST dated 20-06-2012 read with Rule 6(7C) of the Finance Act, 1994 (as amended) the Petitioner was liable to pay service tax as per the prevailing provisions since they had been rendering service to the State Government in relation to promotion, marketing, organising and assisting in organising games of chance including lottery services.

2. The Petitioner is a Company registered under the Companies Act, 1956 and is engaged in the business of sale of lottery tickets organised by the Government of Sikkim, the Respondent No.4, under an agreement dated 10-08-2009 for a term of five years. By that agreement the Petitioner procures the lottery tickets in bulk from the Government of Sikkim and resells those to the public through various agents, stockists, resellers, etc.

3. The Writ Petition is founded on several grounds particularly the jurisdiction of the Respondents No.1 to 3 in demand