Sukhdev Singh Kang, J.

1. The challenge in this bunch of writ petitions is directed against the legality and constitutional validity of Sections 44AC, 206C and 276BB incorporated in the Income-tax Act, 1961 (hereinafter referred to as "the Act"), by the Finance Act, 1988. The petitioners, also impugn the directions (annexure P-1) issued by the Excise and Taxation Commissioners of the States of Punjab and Haryana directing the owners/managers of the distilleries situated within their respective States to treat 40 per cent. of the sale price of alcoholic liquor for human consumption (other than Indian made foreign liquor) (hereinafter, for brevitys sake, referred to as "country liquor") as profits and gains of the buyers (petitioners liquor contractors) from business and recovering income-tax at the rate of 15 per cent. of such profits and gains from the buyers with effect from June 1, 1988. For the purpose of calculating income-tax recoverable from the buyer, a seller shall add the excise duty paid by the purchaser to the State Government on behalf of the seller to the price charged or to be charged for such sale of country liquor.

2. The pleadings in Civil Writ No. 3947 of