GST commissioner accused of relying on AI-generated non-existing and unrelated orders, Gujarat HC stresses regulation
The petitioner firm's advocates drew the Gujarat High Court’s attention to at least three rulings relied on by the CGST department that either did not exist or were incorrectly cited.
3 min readVadodaraUpdated: Feb 25, 2026 02:42 PM IST
The Gujarat High Court observed that the findings recorded by the additional commissioner of the central GST and central excise department were “flawed and deceptive". (File photo)
Stating that there is a need to prescribe “parameters” for quasi-judicial authorities about relying on high court or Supreme Court judgments, the Gujarat High Court issued notices to the central GST and excise department to explain submissions that “appeared” to be made by the department by following “AI-generated citations and case laws”.
A bench of Justice A S Supehia and Justice Pranav Trivedi issued notices to the respondents, the additional commissioner of the Central GST and central excise department and the joint commissioner (anti-evasion), CGST and Central Excise, while hearing a matter concerning a notice issued by the CGST to M/s Marhabba Overseas Private Limited.
The oral order of the court, dated February 20 (made available on Monday), noted that after senior advocate S N Soprkar, who appeared for the petitioner firm, “pointed out a very worrying trend” that the additional commissioner of CGST had, while passing an order on September 26, 2025 against the petitioners, relied on “non-existing judgments” or those that “though in existence… (were) not even remotely connected to the issues” raised by the firm in a reply it had earlier submitted to the department’s showcause notice.
The petitioner’s advocates drew the court’s attention to at least three rulings relied on by the CGST department that, as per their research, either did not exist or were incorrectly cited and attributed to other courts. The submissions also drew attention to the fact that some judgments, though cited correctly, pertained to matters completely different from the issue raised by the petitioner.
Stating that the submissions and the concern expressed by the senior advocate “merits acceptance”, the court order noted, “It is urged by the learned Senior Advocate that some guidelines are required to be prescribed to the quasi-judicial authorities in referring to the judgements blindly generated through Artificial Intelligence, which are not in existence and even if they are in existence, they do not remotely apply to the issues raised by the assessee…”
The court also observed that the findings recorded by the additional commissioner of the central GST and central excise department, by relying on the said judgements and citations were “flawed and deceptive”.
“It appears that the Commissioner, without reading the actual judgments, has followed the AI-generated citations and case law… Hence, we find that this is an appropriate case wherein some directions are called for regulating /prescribing some parameters for quasi-judicial authorities while placing reliance on the judgments either of the High Courts or of the Supreme Court of India while dealing with legal issues raised by an assessee,” the order read.
Story continues below this ad
The court called on the CGST’s senior standing counsel, Ankit Shah, to respond to the concerns by the next date of hearing, March 12, when the matter will be listed on priority.
Aditi Raja is an Assistant Editor with The Indian Express, stationed in Vadodara, Gujarat, with over 20 years in the field. She has been reporting from the region of Central Gujarat and Narmada district for this newspaper since 2013, which establishes her as a highly Authoritative and Trustworthy source on regional politics, administration, and critical socio-economic and environmental issues.
Expertise:
Core Authority & Specialization: Her reporting is characterized by a comprehensive grasp of the complex factors shaping Central Gujarat, which comprises a vast tribal population, including:
Politics and Administration: In-depth analysis of dynamics within factions of political parties and how it affects the affairs in the region, visits of national leaders making prominent statements, and government policy decisions impacting the population on ground.
Crucial Regional Projects: She consistently reports on the socio-economic and political impact of infrastructure projects in the region, especially the Statue of Unity, the Sardar Sarovar Project on the Narmada River, the Mumbai-Ahmedabad High Speed Rail bullet train project as well as the National Highway infrastructure.
Social Justice and Human Rights: Her reporting offers deep coverage of sensitive human-interest topics, including gender, crime, and tribal issues. Her reports cover legal proceedings from various district courts as well as the Gujarat High Court (e.g., the Bilkis Bano case remission, POCSO court orders, Public Interest Litigations), the plight of tribal communities, and broader social conflicts (e.g., Kheda flogging case).
Local Impact & Disaster Reporting: Excels in documenting the immediate impact of events on communities, such as the political and civic fallout of the Vadodara floods, the subsequent public anger, and the long-delayed river redevelopment projects, Harni Boat Tragedy, Air India crash, bringing out a blend of stories from the investigations as well as human emotions.
Special Interest Beat: She tracks incidents concerning Non-Resident Gujaratis (NRIs) including crime and legal battles abroad, issues of illegal immigration and deportations, as well as social events connecting the local Gujarati experience to the global diaspora. ... Read More
