2026-VIL-724-P&H
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SGST High Court Cases

GST – Legality of use of Artificial Intelligence Tool for preparation and issuance of Show Cause Notice - Application of mind by Competent Authority - Petitioner assailed a Show Cause Notice on the ground that there was no application of mind to the facts involved in the case by the Officer concerned, who had resorted to the use of an AI Tool for issuance of the notice - Whether a show cause notice issued primarily relying upon an AI Tool without the requisite sanction in law can be sustained – HELD - The document annexed to the show cause notice referred to various AI-based aids and suggestions with regard to the manner in which the order could be passed or improved and the optional enhancement suggested by the AI Tool included suggestions to tighten the order further with case-law citation, convert it into Order-in-Original reasoning, add knowledge and connivance language and draft a defence-proof rebuttal - The statute expects the competent authority not only to examine the facts of the case but also to apply their mind before issuing a SCN. The use of an AI Tool for preparation and issuance of show cause notice is not shown to be permissible under the statute. Since the show cause notice has been issued primarily relying upon the AI Tool which does not have the requisite sanction in law, the said show cause notice and the consequential proceedings thereof cannot be sustained in law - The show cause notice and the consequential proceedings thereof are quashed. Liberty is reserved with the competent authority to pass a fresh order in accordance with law by examining the facts of the case with independent application of mind – The petition is disposed of
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