Refund claim for zero-rated sales remains valid despite delayed Form-W filing where substantive disclosure was already made.

The 180-day time limit for filing Form-W to claim input tax credit refund on zero-rated sales under Section 18(3) of the Tamil Nadu Value Added Tax Act, 2006 was treated as directory because the taxpayer had already disclosed the relevant transactions in monthly returns and annexures. Form-W was regarded as a consolidated administrative statement, not the source of entitlement, so delayed filing did not extinguish the substantive refund right. The refund claim could not be rejected solely for late submission of Form-W.

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Issues: Whether the 180-day period prescribed for filing Form-W and claiming refund of input tax credit in respect of zero-rated sales under Section 18(3) of the Tamil Nadu Value Added Tax Act, 2006 is mandatory or directory.

Analysis: The petitioner had disclosed the zero-rated transactions in its monthly returns, including the annexures furnished to the Assessing Authority. Form-W was only a consolidated statement for convenience and administrative processing, while the relevant particulars were already available in the returns on a monthly basis. In those circumstances, the statutory time limit for filing Form-W was treated as a procedural requirement and not as a condition that extinguished the underlying entitlement to refund merely because the form was filed beyond 180 days. The earlier decision relied upon also supported the view that a refund claim should not be defeated where the substantive entitlement is otherwise clear.

Conclusion: The 180-day requirement under Section 18(3) was held to be directory, and the refund claim could not be rejected solely on the ground of delayed filing of Form-W.

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