Human Judgment In The Age Of Artificial Intelligence: Lessons From GST Adjudication For The Future Of Legal Decision-Making
Paritosh Garg, JKT And Associates
Introduction
Artificial Intelligence is entering legal practice at remarkable speed. It can search law, compare documents, identify inconsistencies, and assist with drafting. For a system struggling with volume, the attraction is obvious. Yet adjudication is not simple a data problem.
India's Goods and Services Tax (GST) regime is a useful place to assess that assumption. GST proceedings generate scrutiny, show cause notices, determinations, penalties and appeals. Yet adjudication is not simply a data problem. It is deciding what that mismatch means, whether an explanation is credible, whether conduct was deliberate, and what consequence is justified.
This article argues that AI can assist that work but should not replace the human judgment at its centre. GST is the vehicle, not the destination: the same question arises wherever administrative decisions affect rights, liabilities, or reputation.
GST Adjudication Is Not Merely a Data Exercise
The CGST Act itself shows that adjudication is more than calculation. Section 75(4) requires an opportunity of hearing where a written request is made, or an adverse decision is contemplated. Section 75(6) requires the proper officer to set out the relevant facts and the basis of the decision.
Consider two taxpayers who make the same reporting error. On a spreadsheet, the error may look identical. Legally, however, the cases may be quite different. One may have deliberately suppressed a transaction; another may have made a genuine clerical mistake and produced records explaining it. The difference may lie in evidence, intent, and surrounding circumstances. Those are precisely the features that a purely pattern-based system may struggle to appreciate.
The Supreme Court has treated natural justice as a substantive requirement of fair decisionmaking. In Canara Bank v Debasis Das, the Court emphasised the importance of giving an affected person an opportunity to meet the case against them. In Dharampal Satyapal Ltd v Deputy Commissioner of Central Excise, the Court connected fair hearing with reasoned decision-making.
AI can organise documents, identify missing records, retrieve authorities, and highlight inconsistencies. The point is simply that assistance is not adjudication.
