Capital goods input tax credit is subject to the general limitation period, with separate availment rules not overriding it.

Input tax credit on capital goods under the Tamil Nadu Value Added Tax Act, 2006 remains subject to the outer time limit in Section 19(11), which applies to claims for credit on any taxable purchase and does not carve out a separate regime for capital goods. Section 19(3) and Rule 10(4) govern entitlement, intimation of commercial production, and staged availment of credit, but they do not override the statutory limitation period. The Court also noted that failure to comply with the Rule 10(4)(a) intimation requirement independently weakened the claim. The challenge to disallowance of credit was rejected.

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Issues: Whether input tax credit on capital goods under the Tamil Nadu Value Added Tax Act, 2006 could be claimed beyond the time limit prescribed in Section 19(11), and whether Section 19(3) read with Rule 10(4) created a separate regime excluding that limitation.

Analysis: Section 19(3) deals with the entitlement to input tax credit on capital goods and the manner of availing it, while Rule 10(4)(a) and Rule 10(4)(b) prescribe the requirement of intimation of commencement of commercial production and the staged availment of credit over three years. Section 19(11), however, fixes the outer time limit for making a claim for input tax credit in respect of any taxable purchase, and the Court held that the provision contains no distinction between capital goods and other goods. Reading Section 19 as a whole, the Court rejected the attempt to create a separate compartment for capital goods and held that the statutory scheme does not permit an artificial dichotomy between entitlement and availment. The Court also held that non-compliance with the intimation requirement under Rule 10(4)(a) independently weakened the claim.

Conclusion: Section 19(11) applies to claims of input tax credit on capital goods as well, and the writ petitions challenging the disallowance of credit were dismissed.

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