8. Section 206C is not applicable to liquor vendors holding L-13 licences - K.K. Mittal & Co. v. Union of India [1993] 203 ITR 201 (Punj. & Har.). Section 206C is constitutionally valid - T.K. Aboobacker v. Union of India [1989] 177 ITR 358 (Ker.)/A. Sanyasi Rao v. Government of AP [1989] 178 ITR 31 (AP)/Sat Pal & Co. v. Excise & Taxation Commissioner [1990] 185 ITR 375 (Punj. & Har.). Where liquor licence is in the name of partner, but firm was carrying on business, firm must be treated as a ‘seller’ - Bhagwan Singh v. Union of India [1994] 209 ITR 824 (Pat.). State of Bihar will come within the meaning of ‘seller’ - State of Bihar v. CIT [1993] 202 ITR 535 (Pat.). Government distilleries must collect tax at source on country liquor sold to licence holders - Rudra & Co. v. Union of India [1998] 233 ITR 66 (HP). Lessees in Assam are excluded - Bikul Das v. State of Assam [1998] 231 ITR 247 (Gauhati). Person having status of ‘individual’ in income-tax proceedings is not permitted to collect tax under section 206C - Madan Mohan Gupta v. Union of India [1993] 204 ITR 384 (Pat.). Tax is to be collected on total amount of sale consideration and not on sale proceeds - M.A. Majeed v. Divisional Forest Officer [1993] 115 CTR (Ker.) 19. Collection is relatable to purchase price and not to income component - Sat Pal & Co. v. Excise & Taxation Commissioner [1990] 185 ITR 375 (Punj. & Har.). Excise duty element should not be included in cost price - Ramjee Prasad Sahu v. Union of India 1993 Tax LR 593 (Pat.)/Bharat Prasad Choudhary v. Union of India [1998] 229 ITR 363 (Pat.)/Ashok Kumar v. Union of India [1998] 98 Taxman 32 (MP). Purchase price includes excise duty - Circular No. 585, dated 27-11-1990. Purchase and sale of tendu leaves after drying, etc., is not a ‘process’ and hence not exempt from collection of tax at source - North Koel Kendu Leaves and Mahulam Leaves v. Union of India [1997] 228 ITR 630 (Pat.)/Natwarlal v. Union of India [1998] 233 ITR 490 (MP)/Sagarmal Agarwal v. Union of India [1999] 238 ITR 989 (Ori.). For details, see Taxmann’s Master Guide to Income-tax Rules.