G.C.Bharuka, J.

1. The only question which survives for our consideration in this set of writ applications is, as to whether a sum equal to 15 per cent. of the excise duty payable by the petitioners on account of purchase of country spirit can be collected as income-tax under the provisions of Sec. 206C of the Income-tax Act, 1961 (hereinafter in short, " the Act " only).

2. The foundational facts as set out by the petitioners may briefly be stated as below. The petitioners are retail vendors in country spirit, which is an alcoholic liquor meant for human consumption. This privilege has been acquired by them by participating in auction-cum-tender system of settlement of shops envisaged under the provisions of the Bihar Excise Act, 1915 (hereinafter, in short, " the Excise Act " only), and the Rules framed thereunder. Consequent upon the settlements, they have been granted licences in Form No. 26 by the respective Collectors on different dates for the period ending March 31, 1995. Copies of some of such licences have been annexed by some of the petitioners to the respective writ applications. The State Government as a condition for grant of the said privilege has made it man