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    <title>2024 (2) TMI 297 - MADRAS HIGH COURT</title>
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    <description>Unutilised input tax credit on capital goods under the Tamil Nadu Value Added Tax Act, 2006 was treated as eligible for refund because the definition of input under Section 2(23) includes capital goods and Section 18(3) governing zero-rating covers such claims. The refund applications were stated to have been filed within the prescribed 180 days, but processing was delayed due to Circular No. 22/2011, later superseded by Circular No. 12 of 2018, so the delay could not fairly be attributed to the claimant and the limitation objection was unsustainable. Entitlement to refund still required verification against the relevant ITC and export documents, so the merits had to be examined on remand.</description>
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      <description>Unutilised input tax credit on capital goods under the Tamil Nadu Value Added Tax Act, 2006 was treated as eligible for refund because the definition of input under Section 2(23) includes capital goods and Section 18(3) governing zero-rating covers such claims. The refund applications were stated to have been filed within the prescribed 180 days, but processing was delayed due to Circular No. 22/2011, later superseded by Circular No. 12 of 2018, so the delay could not fairly be attributed to the claimant and the limitation objection was unsustainable. Entitlement to refund still required verification against the relevant ITC and export documents, so the merits had to be examined on remand.</description>
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