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of <h1>Guidance on ITC Apportionment in Business Reorganizations: Asset-Based Allocation, State-Level Filing, and Transfer Procedures.</h1> The circular clarifies the apportionment and transfer of input tax credit (ITC) during business reorganizations like mergers, demergers, or ownership changes under the CGST Act and Rules. It specifies that in demergers, ITC should be apportioned based on the value of assets at the state level, not nationwide. The transferor must file FORM GST ITC-02 only in states where both entities are registered. The apportionment formula applies to all reorganization forms involving partial asset transfers. ITC is apportioned across all tax heads collectively, not individually. The relevant ITC balance date is the FORM GST ITC-02 filing date, while asset valuation is based on the appointed demerger date.
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