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Incident Tracker / India

Buckeye Trust v. PCIT-2, Bangalore, ITA No. 1051/Bang/2024

·Income Tax Appellate Tribunal, Bengaluru ('A' Bench)·INOther

In India, the Bengaluru bench of the Income Tax Appellate Tribunal decided a roughly Rs 669 crore private-trust taxation appeal (Buckeye Trust, 30 December 2024) relying in its own reasoning on three non-existent case citations, two attributed to the Supreme Court and one to the Madras High Court. The Tribunal later recalled the order under section 254(2) for fresh hearing.

Court
Income Tax Appellate Tribunal, Bengaluru ('A' Bench)
Date
2024-12-30
Who used the AI
Not recorded
AI tool
Not identified in the record
Conduct
The Tribunal's own order, resolving whether a private discretionary trust's receipt of investments worth about Rs 669 crore was taxable, relied in its reasoning on four case citations, three of which do not exist — two attributed to the Supreme Court and one to the Madras High Court. (Press attributes the fabrications to ChatGPT; the order does not name a tool.)
Outcome
Other
Penalty
No monetary penalty recorded
Regulatory outcome
No separate regulatory disposition recorded
Status
Verified against listed sources
Last checked
2026-09-04

What was fabricated or misused

  • K. Rukmani Ammal v. K. Balakrishnan (1973) 91 ITR 631 (Madras High Court) — no such case could be located; one of the non-existent citations in the order
  • S. Gurunarayana v. S. Narasimhulu (2004) 7 SCC 472 (Supreme Court of India) — no such case could be located; one of the non-existent Supreme Court citations
  • Sudhir Gopi v. Usha Gopi (2018) 14 SCC 452 (Supreme Court of India) — no such case could be located; one of the non-existent Supreme Court citations

What the court said

“Further below mentioned judgments would show that interest in partnership firm is nothing rather shares of partnership firm”
Income Tax Appellate Tribunal, Bengaluru ('A' Bench), p. 28
“K. Rukmani Ammal v. K. Balakrishnan (1973) 91 ITR 631 (Madras High Court) The court observed that a partner's interest in a partnership firm is a species of movable property and can be transferred.”
Income Tax Appellate Tribunal, Bengaluru ('A' Bench), p. 28
“S. Gurunarayana v. S. Narasimhulu (2004) 7 SCC 472 (Supreme Court of India) The Supreme Court held that a partner's interest in a partnership firm is not merely a financial interest but also includes their right to participate in the management of the firm.”
Income Tax Appellate Tribunal, Bengaluru ('A' Bench), p. 28
“Sudhir Gopi v. Usha Gopi (2018) 14 SCC 452 (Supreme Court of India) The Supreme Court held that a partner's interest in a partnership firm is a valuable right and can be the subject matter of a partition suit.”
Income Tax Appellate Tribunal, Bengaluru ('A' Bench), p. 28

Timeline

  1. PCIT order under appeal was made.
  2. Income Tax Appellate Tribunal heard the appeal.
  3. Tribunal pronounced the order containing the disputed citations.

Why this case matters

Buckeye is different from most records because the disputed citations sat in the tribunal's own reasoning rather than in a party filing. Pooja Ramesh Singh later reached the Supreme Court of India after lower insolvency tribunals relied on fake precedents; Buckeye shows the same risk in a tax tribunal order about a Rs 669 crore trust transaction. The order itself does not name an AI tool, so the record should separate the primary fact of non-existent citations from later reporting about ChatGPT.

Practice note

A tribunal bench or research team should verify every cited case in the official reporter, Supreme Court database or High Court source before an order is pronounced. The check should include the party names, citation and holding. If a citation cannot be found, the point should be rewritten using verified law or left undecided until parties can address it.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “Buckeye Trust v. PCIT-2, Bangalore, ITA No. 1051/Bang/2024”, safelegalai.com/tracker/buckeye-trust-itat (accessed 2026-09-16). Data: CC BY 4.0.

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