You see that on earlier versions of windows as well, it will recommend driver updates that are older. I guess it fails on some meta-data checks, or the data added to windows update lacks information to make an "informed decision", or it is just based on "Do you have this driver installed, or the previous one we supplied, if not, then well install it".
I've yet to press the "info" button on any driver updates from Windows Update and get to a web page that tells you what it actually contains, I guess that is up to each hardware vendor to supply information about through some special file in the driver or something, and they never bother to do that.
http://sysdev.microsoft.com/en-US/Hardware/support/default.aspx is the only page I get when I request information on:
Hence I've never trusted it to update any drivers (Currently recommending drivers for INtel System, Intel System, Nvidia Display and OCZ Storage) as there is no information on what any of the updates are.