HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Sankalp Recreation Private Limited v. Union of India and Others
Civil Appeal No. 7438 of 2019
[2019] 12 SCR 661 ·
Income-tax Act, 1961: section 269UD(1)
Sources & disclosures includedDownload original judgment / order
Two-judge bench; judgment delivered by R. F. Nariman, J. · R. F. Nariman, J. · Surya Kant, J.
01 · Facts of the case
The Union acquired a Mumbai property in 1994 under section 269UD(1). After failed auctions, the appellant’s private offer of ₹32.11 crore was not accepted; it later bid ₹30.21 crore against a ₹30 crore reserve. The department kept that process in abeyance, obtained a fresh valuation, cancelled the auction and conducted another auction in which respondent no. 4 was the sole bidder at ₹31.10 crore (SCR pp.661-667; PDF pp.1-7).
02 · Discussion by the Hon’ble Court
The Court held that the record supplied a non-arbitrary reason: the ₹30.21 crore bid was below the appellant’s own earlier offer, fresh valuations had been obtained, public interest favoured securing the highest possible price, and the appellant declined repeated opportunities to participate in the fresh auction. The disclosed report and Finance Ministry letter supported the administrative decision (SCR pp.667-668; PDF pp.7-8).
03 · Judicial decision
The Court dismissed the appeal and held respondent no. 4 to its enhanced ₹35 crore offer. After deducting 9% interest on ₹7.78 crore already lying with the Union, the net amount was to be paid directly to the Union treasury within twelve weeks.
04 · Outcome / in whose favour
In favour of the Union and respondent no. 4; the fresh auction remained undisturbed and the enhanced offer was accepted.
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: for a challenge to disposal of tax-acquired property, preserve the tender conditions, valuation sequence, contemporaneous reports, later explanatory material and bidder participation history. The decision supports record-based judicial restraint; it does not make every reserve-price bid automatically rejectable or confer current Chapter XX-C authority.
Source & verification
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Statutory scope
The property had been acquired under the former Chapter XX-C regime. The operative ruling concerns judicial review of the later government auction; it does not decide an assessee’s tax liability or validate present acquisition powers.
Later treatment
Source checked 2026-10-12. No comprehensive current-law or later-treatment clearance is represented.
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