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(a) "goods" includes computer software;

(b) "properties" includes information technology software;] 15.2 Before us, the appellant has claimed that the appellant, by virtue of being a State within the meaning of Article 12 of the Constitution of India, is not liable to pay any Service Tax. It has been explained by the appellant that having constructed its own buildings, they had let out on rent and collected only water charges from the tenements for supply of water, which was in turn remitted to the concerned State Government department. A sample agreement between the appellant and the Commissionerate Division - III has been placed on record along with sample receipts, apparently to demonstrate that the demand notices were issued to the appellant for paying water charges. This, according to them, was a mere reimbursement of expenditure.