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The HC declined to entertain a petition challenging an AI-generated order that declared the petitioner's tax return invalid for non-filing of an audit report under Section 44AB. The court criticized the impugned order as a "nonspeaking order" that violated principles of natural justice by failing to provide minimal reasoning for rejecting the petitioner's claim that its gross receipts (Rs. 6.15 crores) were below the threshold requiring audit (Rs. 10 crores). While acknowledging the efficiency of automated systems, the HC emphasized that AI cannot supersede fundamental principles of natural justice. Nevertheless, the court directed the petitioner to pursue the alternate statutory remedy of revision under Section 264 of the Income Tax Act rather than exercising extraordinary jurisdiction.
The HC declined to entertain a petition challenging an AI-generated order that declared the petitioner's tax return invalid for non-filing of an audit report under Section 44AB. The court criticized the impugned order as a "nonspeaking order" that violated principles of natural justice by failing to provide minimal reasoning for rejecting the petitioner's claim that its gross receipts (Rs. 6.15 crores) were below the threshold requiring audit (Rs. 10 crores). While acknowledging the efficiency of automated systems, the HC emphasized that AI cannot supersede fundamental principles of natural justice. Nevertheless, the court directed the petitioner to pursue the alternate statutory remedy of revision under Section 264 of the Income Tax Act rather than exercising extraordinary jurisdiction.
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