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HomeGSTClarification Sought Over AI-Generated Case Citations in GST Order: Gujarat High Court...

Clarification Sought Over AI-Generated Case Citations in GST Order: Gujarat High Court Directs No Coercive Action Against Assessee

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The Gujarat High Court has taken note of allegations that an order passed by the Additional Commissioner, Rajkot, relied upon AI-generated judicial citations that allegedly did not correspond with the issues involved in the proceedings and directed the department to clarify the position and, meanwhile, ordered that no coercive steps be taken against the petitioner.

The bench of Justice A.S. Supehia and Justice Vaibhavi D. Nanavati has observed that if it was found that the citations relied upon and incorporated in paragraphs 5, 6 and 7 of the order did not reconcile with the issues raised before the Additional Commissioner, the Court would take a serious view of the matter.

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The petitioner drew the Court’s attention to an order dated August 27, 2025, passed by the Additional Commissioner, Rajkot.

The petitioner specifically alleged that the citations referred to in paragraphs 5, 6 and 7 of the impugned order were AI-generated. According to the submission, the paragraphs and observations attributed to those judicial citations did not reconcile with the issue that had been raised before the Additional Commissioner.

It was further submitted that the judgments cited in the order did not actually deal with the issues that were presented before the authority. 

The allegation therefore raised a question not merely about the use of artificial intelligence in preparing or researching legal material, but about the accuracy and relevance of judicial authorities relied upon in a quasi-judicial order.

The petitioner also challenged the recording made by the Additional Commissioner in paragraph 9.1 of the order.

According to the petitioner, the authority had incorrectly recorded that the petitioner had neither filed a defence reply nor sought an extension of time for filing the defence reply.

Counsel referred to a communication dated July 21, 2025, submitted by the petitioner. According to the submissions recorded by the High Court, the communication sought postponement of the hearing as well as an extension of time for filing a reply to the show cause notice.

The petitioner further claimed that the same communication had sought cross-examination of various witnesses and requested access to documents that had allegedly been impounded during the investigation. 

After hearing the submissions, the Division Bench observed that it found merit in the petitioner’s submissions at this stage, subject to instructions being obtained by the Senior Standing Counsel appearing for the respondents.

The Court specifically focused on the alleged mismatch between the citations relied upon in the Additional Commissioner’s order and the issues that had actually been raised before the authority.

The observation is significant because it places emphasis on the requirement that judicial authorities relied upon in an adjudicatory order must actually correspond to the legal issues under consideration.

The High Court consequently issued notice to the respondents, making it returnable on September 29, 2026.

Senior Standing Counsel Ms. Hardika Vyas waived service of notice on behalf of the respondents. The matter was also directed to be listed on top of the board. 

As an interim measure, the Gujarat High Court directed that no coercive step shall be taken against the petitioner in the meantime.

Thus, pending the respondents’ response and the Court’s further consideration of the issues raised, Riya International has been protected from coercive action arising from the impugned proceedings. 

The proceedings are now scheduled for further consideration on September 29, 2026. 

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Read More: GST Registration Cancellation Can’t Be Based on Unquantified ITC Mismatch Before Verification of Suppliers: Calcutta High Court

Nikhil Bhandari
Nikhil Bhandari
Nikhil Bhandari is a Chartered Accountant and a Indirect Tax professional with over 5 years of post-qualification experience in tax advisory, compliance management, and tax process optimization. Associated with SDU LLP since August 2015 spanning his articleship through to his current role as Assistant Manager Nikhil has uniquely navigated India’s transition from the legacy tax regime into the GST era.His expertise encompasses both strategic advisory and Indirect Tax litigation, where he represents clients in complex disputes across the manufacturing, service, and e-commerce sectors. By providing high-level counsel to corporate leadership, he ensures that tax positions are not only robust and compliant but also structured for long-term operational efficiency.Beyond his core practice, Nikhil is a proactive contributor to the GST ecosystem. He is dedicated to tracking and analyzing judicial precedents from various High Courts and the Supreme Court, fostering greater clarity and ease of access to tax intelligence for the wider professional community.

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