Assessee association was engaged in manufacturing of bidi.  Assessee had appointed agents/contractors who after purchasing tendu leaves from State forest department and after carrying out activities of drying, sprinkling of waters, sorting and screening of leaves, bundling it, etc., supplied same to assessee for manufacturing of bidis. Assessee filed writ petition stating that there contractors of tendu leaves were entitled to exemption under S. 206C(1) while purchasing tendu leaves from State forest department. Dismissing the petition the Court held that processing of tendu leaves would qualify as trading or sale, but not as manufacturing thus, contractors were liable to pay TCS on purchasing such tendu leaves from State forest department and they were not eligible for benefit of exemption under S. 206C(1A) of the Act.  Petition was dismissed.