In migrations you normally copy the file system elsewhere, to the cloud or to different computers, you do not shrink it in place, which is what XFS cannot do. Unlike with Windows, copying Linux file systems, including XFS, during migrations to different hardware is trivial and fast. The same is true for multiplicating a file system to a big set of computers.
Shrinking in place is normally needed only when you share a physical device between 2 different operating systems, which use incompatible file systems, e.g. Windows and Linux, and you discover that you did not partition well the physical device and you want to shrink the partition allocated for one of the operating systems, in order to be able to expand the partition allocated for the other operating system.
Sharing physical devices between Windows and any other operating systems comes with a lot of risks and disadvantages, so I strongly recommend against it. I have stopped sharing Windows disks decades ago. Now, if I want to use the same computer in Windows and in another operating system, e.g. Linux or FreeBSD, I install Windows on the internal SSD, and, when desired, I boot Linux or FreeBSD from an external SSD. Thus the problem of reallocating a shared SSD/HDD by shrinking a partition never arises.