Dismissing the appeal the Court held that, several auctions were conducted from the year 1994, including an auction as recent as March 27, 2017 which failed to elicit a response from any buyer. Ultimately, the auction with the reserve price of Rs. 30 crores, on which the appellant’s bid was Rs. 30.21 crores, was kept in abeyance because in a report dated September 26, 2017 it was pointed out that this figure was considerably lower than the figure offered by the appellant itself at Rs. 32.11 crores and that, therefore, a fresh auction be held. This reason was not, in any manner, arbitrary. After all, it was in public interest to see that the highest possible price be fetched for such properties. Further, at every stage valuation reports were submitted by reputed valuers, first from Mumbai, and then from Chennai, and there was no reason to doubt what had been stated to be the fair market value in any of these reports. Though the appellant was given several opportunities to bid in the fresh auction conducted, ultimately, for reasons best known to it, it chose to refrain from participating therein. So long as the auction process was conducted bona fide and in public interest, a judicial hands-off was mandated. Ordinarily, reasons must inform all Governmental decisions including administrative decisions of the Government so that both the administration as well as challenges made to such orders, could be said to be fair and not arbitrary. The reasons disclosed both in the report dated September 26, 2017 and the letter dated April 6, 2018 from the Government of India, Ministry of Finance, to the Chief Commissioner of Income-tax, made it clear that there was no arbitrariness discernible in the entire auction process.

Court also held that respondent No. 4 to the offer made to the court. From the figure of Rs. 35 crores, which was to be paid within a period of 12 weeks directly to the Union treasury, a sum equivalent to interest of 9 per cent. on the amount of Rs. 7.78 crores, lying with the Union, calculated from the date on which it was deposited with the Union till date shall be subtracted, and the net figure handed over.