GFCI protection interrupts a circuit when current returns by an unintended path — through a person, for example — and it is required in locations where water, damp conditions or grounded surfaces raise the risk of that happening. Garages are on that list because of concrete floors, moisture, vehicle washing and the outdoor tools that get plugged in there. An older garage receptacle without protection was probably compliant when installed, since the requirement was extended to garages at a particular point in the code's history, so the inspector is not reporting a violation of the rules in force at the time. What they are reporting is a present-day safety gap with an inexpensive remedy, which is exactly the shape of a recommended safety upgrade: note the condition, explain the risk, recommend the improvement without characterizing the original work as defective.