The instructions said that AI can only assist decision-makers. Any judgment, statutory provision, rule, circular or notification identified through AI must be independently verified from primary official sources before being incorporated into an order.
If an AI tool paraphrases the ratio of a judgment, tax officers have to locate the original paragraph and reproduce it before relying upon it. Authorities must also verify whether judgments remain good law and record reasons when decisions cited by taxpayers are held to be inapplicable.
Significantly, the instructions said that AI cannot substitute the independent application of mind by the adjudicating authority.
“Orders must reflect independent legal reasoning and record the officer’s own application of mind to the law and the facts of the case. AI output may assist in reasoning but cannot substitute it.”
The Court took recorded the same in its order.