GST Tax Payment Regarding

Dear Experts,

In a case, my client who was registered under GST died. His wife got registered under GST (with deceased proprietor registration option) and now we have to transfer stock (amounting rs 50 lac with 12% item) of the previous firm (husband's) to the new one (wife's). Now the tax advocate is saying that they need to pay Tax on transfer of stock as there's nothing left as ITC in their Tax kitty.

Is there any way out to avoid that tax payment of rs 600000 (6 Lac).

Please suggest.

Thanks in advance.