As per case facts, appellants, registered dealers in various businesses, were denied Input Tax Credit (ITC) under the Tamil Nadu VAT Act, 2006, because they failed to claim it within ... the time limit stipulated by Section 19(11). They argued that delays in receiving original tax invoices caused the late claims. Consequently, they appealed the High Court's dismissal of their writ petitions, which challenged the constitutional validity of Section 19(11) as arbitrary, unreasonable, and violative of fundamental rights, and inconsistent with the Act's broader scheme. The question arose whether Section 19(11), which mandates a time limit for claiming Input Tax Credit, violates constitutional articles, is inconsistent with other sections of the Act, is merely a directory provision, or if authorities have the power to extend this period. Finally, the Supreme Court ruled that ITC is a concession granted by the legislature, subject to strict compliance with its conditions, including the time limit under Section 19(11). This provision is mandatory, and its language, using "shall," does not permit any other interpretation. The Court found no basis for extending the prescribed time, as taxing statutes are to be strictly construed, and no authority under the Act has the power to dilute this mandatory requirement, thereby dismissing all appeals.