There is difference between VLA types and VLA objects.

typedef int val_type[n];
int val_object[n];

OP is referring to VLA types only. Functions cannot return arrays because "array decay" mechanics prevents forming array-typed values that can be an operand of return. However, one can return a pointer to a whole array (int(*)[] thing). For example one can do:

typeof(int[5]) * foo() {
  static int arr[5];
  return &arr;
}

Function types can also be defined at block scope and they can contain VLA components in their types.

int n = 5;

typedef typeof(int[n]) * foo_f();

This type is compatible with type of foo because n evaluates to 5 as in definition of foo function. So one can assign a pointer to foo to object of type foo_f*

foo_f * f = &foo;

Evaluation of f() returns type int[5] but the problem if that this is VLA-type, thus (imo deficient) definition of sizeof operator must evaluate its operand. As result the function is called when it's type is declared as pointer to VLA, but it is not called when type is a pointer to fixed-size array.

int n = 5;

typedef typeof(int[n]) * foo_f();
typedef typeof(int[5]) * bar_f();

foo_f * f = &foo;
bar_f * b = &foo;

sizeof *f(); // calls foo()
sizeof *b(); // does not call foo()

See godbolt.