ITC Merger/Acquisition/Transfer: unutilised input tax credit may be transferred on change in business constitution, with asset-based apportionment. A change in constitution (sale, merger, demerger, amalgamation, lease or transfer) allows transfer of unutilised input tax credit from the transferor's electronic credit ledger to the successor, subject to certification that liabilities transfer and acceptance by the transferee on the common portal; the transferee must record received inputs and capital goods. When separate registrations are created within a State/UT, credit is apportioned among new registrations in proportion to the value of entire assets held by each unit at registration, irrespective of whether credit was claimed on those assets. For supply of capital goods with prior credit, the person must pay the higher of adjusted credit or tax on transaction value.