J U D G M E N T

NAGARATHNA, J.

Leave granted in SLP (Civil) No.21584 of 2012.

2. These appeals are filed by the assessees against the Signature Not Verified Digitally signed by Nisha Khulbey Date: 2024.09.0j3udgments of the High Courts of Sikkim and Kerala dated Reason:

03.07.2010 and 19.08.2011 respectively.

3. In K. Arumugam vs. Union of India, C.A. No. 2842-2848 of 2012, the facts are that the appellant is registered with the Directorate of State Lotteries in Thiruvananthapuram and has purchased Kerala State Lotteries from the District Lottery Offices and other States’ lotteries in bulk from registered promoters at a discounted rate. The appellant contends that this purchase was made on an outright sale basis, meaning, they bought all tickets in bulk with no return policy ("all sold basis") and subsequently sold them to retailers, also on an outright sale basis. A profit was made from the difference between the amount received from retailers and the amount paid to the State Government or registered promoters. The sale of lotteries in Kerala was regulated by the Kerala State Lotteries and Online Lotteries (Regulation) Rules, 2003 framed under Section 12(3) of the Lotteries Regulation