TaxTMI 
TaxTMI 
2026 (8) TMI 1389
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....ed that the State Tax Officer Unit-67 has relied upon the case laws, which do not even remotely deal with the issue raised before him. He has submitted that the judgement in the case of State of Gujarat v. Aarbee Structures Pvt. Ltd., 2024 (4) TMI 951 is not in existence, whereas the decision of the Madras High Court referred therein in the case of M/s. Sri Vinayaga Agencies v. Assistant Commissioner, 2023 (5) TMI 106 has different citation and ratio will not apply to the present case. Finally, the decision of the Calcutta High Court in the case of Jyoti Tar Products Pvt. Ltd. v. Deputy Commissioner, 2024 (7) TMI 512 also does not match with any of the citations and ratio also does not apply. 2. It appears that the impugned order h....
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....ed by the Office of the Additional Commissioner of State Tax dated 18/08/2026. All the documents tendered before us, are ordered to be taken on record. 3. The Affidavit-in-reply filed by the respondent no.5 Shri Devang Arvindkumar Yadav, State Tax Officer, who has passed the impugned order, which has been referred by us, in our order dated 13/08/2026, has tendered an unconditional apology for citing the judgments in the impugned order, which are, in fact, cited by using the Artificial Intelligence (AI). The affidavit-in-reply (tendering unconditional apology), specifically refers that the deponent is a probationary officer and due to his lack of experience, the mistake has happened and he has tendered unconditional apology to this Court ....
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....August 2026). The High Court observed that the impugned order was passed by the State Tax Officer by placing reliance exclusively on AIgenerated case laws, which were non-existent or irrelevant. Relevant extract (para 2): "It appears that the impugned order has been passed by the State Tax Officer by placing reliance exclusively on the AI generated case laws." Hon'ble High court has taken the cognizance of the same and therefore, these instructions are issued in order to maintain discipline and uniformity in passing of orders by the officers across the state. 2. Following instructions shall be required to consider while using Al for drafting orders: i. AI use is to assist the Authorities. Any....
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....he facts of the case. AI output may assist in reasoning but cannot substitute it. 3. The ultimate responsibility for the correctness of the order lies with the issuing authority, irrespective of the technological tools used by the authority. 4. Failure to follow these instructions, including passing orders based on unverified AI content, will amount to misconduct and may attract disciplinary action. 5. In view of the above, you are instructed to suitably sensitize the officers under your jurisdiction regarding the above instructions and ensure strict compliance so as to maintain accuracy, consistency, and legal sustainability in adjudicating proceedings. 6. This issue with the approval of the Chief Commis....