In Brief
This case concerns the correct interpretation of "previous Financial Year" under the Odisha Minor Mineral Concession Rules, 2016 for a sand quarry lease tender. The Tender Committee rejected the highest bidder (Rs. 2,127.27/m³) for failing to submit Income Tax Returns for FY 2021-22, accepting instead a lower bid (Rs. 1,250/m³). The Supreme Court held that "previous Financial Year" means the year immediately preceding the tender (FY 2020-21), not FY 2021-22, interpreting the rule harmoniously with the Income Tax Act, 1961. Since the tender was issued mid-year and the ITR filing deadline for FY 2021-22 was still pending, the Committee's rejection was erroneous. The Court struck down the High Court's order and directed a fresh auction, emphasizing that public tenders are exercises in public trust where authorities must maximize State revenue fairly and transparently.
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