As per case facts, an entity amalgamated into the Petitioner, which subsequently sought a refund of unutilized Input Tax Credit (ITC) from the transferor's ledger, arising from exports made before ... amalgamation. The transferor had partially transferred ITC to the Petitioner but retained a portion, for which it filed refund applications. These refunds were initially sanctioned but later set aside by the Respondent's appellate order, leading to the Petitioner filing writ petitions. The question arose whether the transferor was mandated to transfer its entire unutilized ITC to the transferee post-amalgamation, and if the transferor could claim a refund for the retained ITC after amalgamation and its registration cancellation. Finally, the High Court identified flaws in both parties' and the officer's actions. It held that the statute does not permit partial ITC transfer and subsequent refund by the transferor in this manner. Emphasizing strict interpretation of taxing statutes, the court declined to interfere with the impugned orders, dismissing the petitions.