Cross state ITC transfer on amalgamation cannot be blocked by GST portal restrictions; statute governs entitlement.
The court held that Section 18(3) permits transfer of unutilised ITC on amalgamation without an express territorial restriction, Rule 41 and portal procedures cannot add a state based bar, and Section 25(4)'s separate registration concept governs levy and compliance rather than extinguishing statutory credit transfers; technological or administrative constraints must yield to statutory entitlement, with manual facilitation directed pending GSTN backend upgrades where no revenue loss arises. (AI Summary)