Kobelco Construction Equipment India Pvt. Ltd. ., In re

FULL TEXT OF THE ORDER OF AUTHORITY FOR ADVANCE RULING, ANDHRA PRADESH

1. M/s Kobelco Construction Equipment India Pvt Ltd, 4100, Central Expressway, 355 & 505, Palmyra Road, Sri City, DTZ, Tirupati District, Andhra Pradesh – 517646, (GSTIN No. 37AACCK9469N1ZN) (hereinafter referred to as applicant) has filed an application in FORM GST ARA-01 under Section 97(1) of the Central Goods & Services Tax Act, 2017 and AP Goods & Services Tax Act, 2017 (hereinafter referred to CGST Act and APGST Act respectively).

2. At the outset we would like to make it clear that the provisions of CGST Act, 2017 and APGST Act, 2017 are in parimateria and have the same provisions in like matter and differ from each other only on a few specific provisions. Therefore, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act, 2017 would also mean reference to the corresponding similar provisions in the APGST Act, 2017.

3. It is observed that the queries raised by the applicant fall within the ambit of Section 97 of the GST ACT. The applicant attached copies of challans as proof of payment of Rs.5,000 each for CGST and SGST through Electronic Cash Ledger Reference Nos. DC3705250015835 dated 08.05.2025, and DC3705250028170 dated 14.05.2025 respectively, towards the Advance Ruling fee. The Applicant has declared that the questions raised in the application have neither been decided by nor are pending before any authority under any provisions of the GST Act.

4. Brief Facts of the case:

M/s Kobelco Construction Equipment India Pvt Ltd is engaged is a manufacturer of excavators that established its manufacturing unit in Sri City. It supplies the equipment pursuant to the orders that would be picked up by its respective branches.

Sri City Private Limited has granted 9.3 acres of land on lease to Kobelco Construction Equipment India Private Limited for a lease period of ninety-nine (99) years, and now it is intended to transfer the leasehold rights in favour of India Metal One Steel Plate Processing Private Limited (IMOP) for the remaining unexpired lease period of eighty-nine (89) years for a total consideration of Rs.15,38,00,000/- out of which Rs. 4,03,00,000/- is towards the development of land road structures and facilities and Rs.11,35,00,000/-towards the value of land. Further, it is stated that it has to pay approximately 3.06 million towards lease hold rights commission to Sri City Private Limited. The tax implications on the transfer of leasehold rights are now under consideration in this ruling.

5. Statement of relevant facts having a bearing on the question(s) raised.

A. Sri City Private Limited (“Lessor”) is the absolute owner of the lands situated in Satyavedu and Varadaiahpalem Mandals, Chittoor District, Andhra Pradesh, acquired for the purpose of developing a mixed-use and integrated industrial park, comprising commercial, residential, and recreational facilities, as well as Special Economic Zone (“SEZ”), Domestic Tariff Zone (“DTZ”), and Free Trade Warehousing Zone (“FTWZ”) components (collectively referred to as “Sri City”).

B. A portion of the land (“Demised Premises”) forming part of the DTZ, admeasuring 9.35 acres, was leased to Kobelco Cranes India Private Limited (“Initial Lessee”), pursuant to a Lease Deed dated 29th May, 2015 (“Lease Deed”), registered as Document No. 520/2015, Book 1 in the office of the Sub-Registrar, Satyavedu.

C. The Initial Lessee, having been in lawful possession of the Demised Premises pursuant to the Lease Deed, has, at its sole cost and expense and in accordance with the terms of the Lease Deed and applicable laws, built the premises.

D. Pursuant to an order dated 18th September, 2017, the National Company Law Tribunal, New Delhi (NCLT) sanctioned a Scheme of Amalgamation under Sections 230–232 of the Companies Act, 2013, whereof the Initial Lessee has merged into the Kobelco Construction Equipment India Private Limited (Transferor), by virtue of which all rights, title, interest, duties, obligations, assets, and liabilities of the Initial Lessee, including but not limited to leasehold rights in the Demised Premises and ownership of the Superstructure, have legally vested to the Transferor by operation of law.

E. Pursuant to Clause 4(2) of the Lease Deed executed in respect of the Demised Premises, the Transferor has approached the Lessor, to exercise its first right of refusal concerning the leasehold rights. The Transferor has further expressed its intent to transfer the leasehold rights in favour of the India Metal One Steel Plate Processing Private Limited (Transferee) in the event the Lessor elects not to reacquire the Demised Premises. Upon discussions between the Lessor and the Transferor, the Lessor has further recommended the execution of MOU to outline the preliminary terms and conditions governing such transfer.

F. The Transferor, desirous of divesting its leasehold rights, title, interest, and obligations in the Demised Premises, together with all rights, title, and interest in the Superstructure, has agreed to transfer the same in favour of the Transferee, subject to the terms and conditions set forth in MOU dated 13.06.2025, and with the express consent and approval of the Lessor.

G. The Parties acknowledge and agree that the proposed transfer of leasehold rights shall include the transfer of the Superstructure on an “As is where is basis”, “as is what is basis”, “whatever there is basis” and “no recourse basis”, together with all attendant rights, obligations, liabilities, and interests associated therewith, and shall be subject to obtaining all necessary consents, approvals, and regulatory compliances, as may be required under applicable law.

H. The Parties further acknowledge and agree that as per MOU is intended to record their mutual understanding of the principal terms and conditions governing the proposed transfer of leasehold rights along with the Superstructure and shall serve as the basis for negotiating and executing a definitive “Agreement for the Transfer of Leasehold Rights”, upon completion of all necessary formalities.

I. The Lessor had originally granted a lease of the Demised Premises to the Transferor for a period of ninety‑nine (99) years, commencing from 29^th May, 2015 (“Original Lease Term”), under the Lease Deed executed between the Lessor and the Transferor. By virtue of the transfer, the Transferee shall be entitled to the remaining unexpired term of the lease, being a period of eighty-nine (89) years, subject to the same terms, conditions, covenants, and obligations as set forth in the Lease Deed and the Agreement for the Transfer of Leasehold Rights, unless otherwise modified therein.

J. In consideration of the transfer of leasehold rights in the Demised Premises, together with the Superstructure and all improvements and appurtenances thereon, the Transferee agrees to pay a sum of Rs 11,35,00,000 (Rupees Eleven Crores and Thirty-five Lakhs only) (“Property Transfer Value”) and Rs 4,03,00,000 (Rupees Four Crores and Three Lakhs only) (“Recovery of Cost of Land Development”) to the Transferor, subject to the terms and conditions set forth in the Agreement for the Transfer of Leasehold Rights.

K. The Transferee shall be entitled to transfer the leasehold rights for the remaining term of the lease in the entire Lease Land in favour of a third party provided that the Transferee shall offer a ‘right of first offer’ (“ROFO”) to the Lessor to take back the Lease Land, at a value that has been agreed between the Transferee and the third party. In case the Lessor declines the offer of taking back the Lease Land, then the Transferee shall be entitled to transfer the leasehold rights to any third party holding valid letter of approval from the Development Commissioner, at cost not less than the cost offered to the Lessor, with prior approval of the Lessor. In case of the transfer of leasehold rights in the Lease Land, to a third party the Transferee shall pay a transfer fee of 15% of the total consideration agreed with such transferee and documented for the Lease Land along with infrastructure thereof (which shall not include building, machinery, equipment and any other infrastructure put up by the Transferee within the Lease Land) proposed to be so transferred.

Under section 7 taxing the lease hold rights transferred by the SEZ to Kobelco in turn transferred by the Kobelco to India Metal One Steel Plate Processing Private Limited (i.e. IMOP) is taxable under the GST Act, if so, whether Kobelco would get any input tax under section 16 and whether the Kobelco would get input tax on the commission on lease hold rights.

6. Questions raised before the authority:

The applicant sought advance ruling on the following:

1. Whether assignment of leasehold rights of leasehold land would be covered by the scope of supply for levy of Goods and Service tax under Section 7 of Central Goods and Services Tax Act, 2017 ? if so whether Goods and Service Tax is applicable on the consideration of Transfer of Leasehold land paid by India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

2. Whether Recovery of Cost of Land Development and related other cost is the supply of Service for levy of Goods and Service tax under definition of Section 7 of Goods and Service tax Act, 2017 If so whether Goods and Service Tax is applicable on Recovery of cost of land Development paid India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

3. Whether Kobelco Construction Equipment India Pvt Ltd is entitled to Input Tax Credit of Goods and Service tax paid on the commission to be paid in relation of the transfer of leasehold land to Sri City Development Authority, under the provision of Goods and Service Tax Act 2017?

On Verification of basic information of the applicant, it is observed that the applicant is under State jurisdiction i.e, Special Circle, Chittoor Division. Accordingly, the application has been forwarded to the jurisdictional officer and a copy marked to the Central Tax authorities to offer their remarks as per Sec. 98(1) of CGST /APGST Act 2017.

In response, remarks are received from the State jurisdictional officer concerned through mail dated 31-05-2025 stating that no proceedings are pending with the issue, for which the advance ruling sought by the applicant.

7. Applicant’s Interpretation of Law:

1. Relevant Legal Provision:

1.1 Section 7 of the Central Goods and Service Tax Act 2017, which is the charging section, encompasses all the supplies of goods and services, including lease and rental activities, making them subject to Goods and service tax.

1.2 Schedule III of the Goods and Service Tax Act 2017 enumerates activities that will neither be treated as “Supply of goods” nor as “Supply of Services,” making them exempt from Goods and Service Tax liability. Sale of Land is one such transaction listed in Schedule III, exempting it from Goods and Service tax.

2. Interpretation of Sale of Land

2.1 While the Central Goods and Service Tax Act define “Supply,” it does not explicitly define “Land.” In the absence of this definition, Courts may refer to other laws for interpretation.

2.2 Various land laws in India, such as the Land Acquisition Act, 1894; the Gujarat Land Revenue Code, 1879; the Andhra Pradesh Land Revenue Code, 1999; the Indian Registration Act, 1908; and the General Clauses Act, 1897, unanimously define “Land” or “immovable property” to include benefits arising out of land.

2.3 Since leasehold rights confer benefit over land for a certain period, it

can constitute “benefits arising out of land” and thereby assignment or transfer of rights of leasehold land qualifies as “Sale of Land.”

2.4 The Assignment or transfer of rights of Leasehold land should be seen as transfer of leasehold rights of immovable property deemed to be “Sale of Land.” So it is exempt from Goods and Service tax under Schedule-III of Central Goods and Service Tax Act 2017.

3. Legal Precedents

The Gujarat High Court’s decision in Gujarat Chamber of Commerce and Industry & Ors. v. Union of India & Ors. provides much-needed clarity on the applicability of GST on the assignment of leasehold rights. The judgment holds that the assignment of leasehold rights in the land allotted by Gujarat Industrial Development Corporation (“GIDC”) constitutes a transfer of immovable property, thus falling outside the purview of GST.

4. ABOUT THE COMPANY:

A. The Applicant Company is a manufacturer of Excavators which set up the manufacturing unit pursuant to the orders by the company specifically under 2 types. The supply of the equipment would be pursuant to the orders that would be picked up by its respective branches.

a. The Company has established as it was promised by then the Chief Minister Shri N. Chandrababu Naidu after declaring certain area as DTZ and after pronouncing certain exemptions. Believing those statements and orders the Company has set up its industry in Sricity and is doing business from then onwards.

b. Recently the Hon’ble Apex Court in the case of Safari Retreats after the introduction of Goods and Service Tax Act 2017 has decided that the Plant & Machinery cannot be subjected to tax as the same is immovable property and applying the same analogy the Leasehold transactions cannot be subjected to tax.

c. Sri City Private Limited has granted the place to set up its industry in 9.3 Acres of land which Kobelco Construction Equipment India Private Limited is proposing to give to India Metal One Steel Plate Processing Private Limited (i.e. IMOP) on lease and the tax on transfer of leasehold rights is now sought in this ruling.

B. Whether the leasehold rights to the portion of land that is allotted by the would be covered by the Goods and Service Act, 2017 and same would fall under the supply of leasehold rights under Section 7 of the Goods and Service Tax Act, 2017.

C. Whether the amount of recovery of land development and other charges is taxable under Goods and Service Tax Act 2017. The recovery of land development and other charges is taxable under the scope of supply of services leviable under section 7 of the Goods and Service Tax Act?

D. Whether the judgment of Safari retreats would apply or not as the Hon’ble Apex Court’s judgment is in a different context, the analogy is same.

E. Whether leasehold rights in connection to immovable property would fall within the definition of ‘service’ and within the scope of section 7, if yes then whether input tax credit is allowable under section 16 of the Goods and Service Tax Act 2017.

F. Whether the tax paid under Section 7 of the Act would be eligible to the input tax credit under the Goods and Service Tax Act 2017 as it would be paid on leasehold rights commission paid to Sri City Private Limited which would come to approximately 3.06 million under section 16 of the Goods and Service tax Act 2017?

G. If it is ruled that no input tax credit is available then what happens to the tax paid?

The view of the applicant is that no tax can be levied on lease hold rights granted by the SEZ units to M/s Kobelco Construction Equipment India Pvt Ltd, which in turn transfers the lease to IMOP, as it is with regard to immovable property, the same cannot be taxed in view of the judgment rendered by the Hon’ble Apex Court in case of Safari retreats and the applicant is eligible to claim input tax credit on both the leasehold rights and also the Commission if the same is taxable.

8. Personal Hearing:

The proceeding of Personal Hearing was conducted on 21.07.2025, for which the authorized representatives, Sri M.V.J.K. Kumar, Advocate and Santosh Kumar, Chartered Accountant have appeared and reiterated the facts narrated in their application.

The Authorized Representative, Sri M.V.J.K. Kumar, Advocate, contended that M/s Kobelco Construction Equipment India Pvt Ltd is assigning lease hold rights to M/s India Metal One Steel Plate Processing Pvt Ltd, Sricity, with the permission of Sri City Pvt Ltd, for a sum of Rs. 15,38,00,000/-, out of which Rs. 4,03,00,000/- is towards the development of land, roads, streets, and facilities.

The Authorized Representative sought an Advance Ruling on the following points:

1. Whether assignment of leasehold rights of leasehold land is covered under the scope of supply for levy of Goods and Services Tax (GST)?

2. Whether recovery of cost of land development and related expenses is considered a supply of service liable to GST under the relevant provisions?

3. Whether M/s Kobelco Construction Equipment India Pvt Ltd is entitled to claim Input Tax Credit (ITC)?

The Authorized Representative submitted copies of-

i) The orders of the Hon’ble High Court of Gujarat at Ahmadabad, in Gujarat Chamber of Commerce and Industry & Ors. Vs.Union of India & Ors. in Special Civil Application No. 11345 of 2023 pronounced on 03/01/2025.

ii) The orders of the Hon’ble High Court of Gujarat in the case of Dhiraj Can Co. Pvt. Ltd. vs. The Union of India & ORS vide R/Special Civil Application No.3596 of 2025 dated 4.7.2025 and

iii) Transfer of lease agreement dated 26.6.2025 by and between M/s Kobelco Construction Equipment India Ltd and India Metal One and Steel Plate Processing Private Limited and Sri City Private Limited.

iv) Lease Deed dated 29.5.2015, between Sri City Private Limited and M/s Kobelco Construction Equipment India Ltd.

v) Memorandum of Understanding dated 13.6.2025 by and between M/s Kobelco Construction Equipment India Ltd and M/s India Metal One Steel Plate Processing Private Limited.

vi) Payment details received by M/s Kobelco Construction Equipment India Ltd from M/s India Metal One Steel Plate Processing Private Limited.

vii) Copy of Transfer fee invoice No.LDCO/25-26/1479, dated 17.6.2025 issued by Sri City Private Limited to M/s Kobelco Construction Equipment India Ltd.

9. Discussion and Findings:

M/s Kobelco Construction Equipment India Pvt Ltd, a private limited company duly incorporated under the Companies Act, 1956, and holding GSTIN: 37AACCK9469N1ZN. The company has its manufacturing unit located in Sri City,

Tirupati District, Andhra Pradesh. The application, filed in Form GST ARA-01 on 08.05.2025, seeks advance ruling under Section 97(1) of the CGST Act and APGST Act, 2017, regarding tax implications on assignment of leasehold rights and eligibility for Input Tax Credit (ITC) on incidental charges. The Acts being pari materia in nature, identical provisions apply unless specifically distinguished.

The applicant is engaged in the manufacture and supply of earth-moving equipment, mainly excavators. The decision to establish operations in Sri City Industrial Township was based on a combination of policy incentives, promises of infrastructural support, and long-term leasing of land within the Domestic Tariff Zone (DTZ) of the said township. Sri City Private Limited, the developer of the township, allotted 9.3 acres of land on a 99-year lease to the applicant. The lease facilitated the setting up of a modern manufacturing facility that now proposes to exit the property and transfer the remaining leasehold interest.

The applicant, as part of its business restructuring, has proposed to transfer the remaining leasehold interest—spanning 89 years—to M/s India Metal One Steel Plate Processing Pvt Ltd, a company engaged in allied manufacturing. The total consideration for the transaction is valued at Rs. 15.38 crore. This includes Rs. 11.35 crore towards the value of leasehold rights (i.e., the right to occupy and use the land for the unexpired lease term), and Rs. 4.03 crore as compensation for the infrastructural development made by the applicant such as roads, drains, compound wall, and allied civil structures. Additionally, a transfer fee/commission amounting to approximately Rs. 30.6 lakh is to be paid by the applicant to Sri City Private Limited, the original lessor.

The Authority has carefully examined the documents placed on record, legal provisions under the CGST and APGST Acts, as well as submissions made during the personal hearing. Each issue is examined in detail below:

1. Whether assignment of leasehold rights of leasehold land would be covered by the scope of supply for levy of Goods and Service tax under Section 7 of Central Goods and Services Tax Act, 2017 ? if so whether Goods and Service Tax is applicable on the consideration of Transfer of Leasehold land paid by India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

The applicant contended that since lease hold rights confer benefit over land for certain period, it can constitute ‘benefit arising out of land’ and thereby assignment or transfer of rights of lease hold land qualifies as ‘Sale of Land’ and is exempt from Goods and Service Tax under Schedule-III of Central Goods and Service Tax Act, 2017. The applicant relied on judgement of Hon’ble High Court of Gujarat at Ahmedabad, in Gujarat Chamber of Commerce and Industry & Ors. Vs. Union of India & Ors. in Special Civil Application No. 11345 of 2023 pronounced on 03/01/2025 and judgement of the Hon’ble Apex Court in the case of Safari Retreats.

Though the Hon’ble Gujarat High Court has held that the assignment of leasehold rights in land allotted by the Gujarat Industrial Development Corporation (GIDC) constitutes a transfer of immovable property and is outside the purview of GST, this view may not align with the statutory framework and intent of the GST regime. The aforesaid judgment has been assailed before the Hon’ble Supreme Court of India by way of Special Leave Petition bearing No. 25536/2025, which is presently pending adjudication.

Under the Central Goods and Services Tax (CGST) Act, 2017, the assignment or transfer of leasehold rights is generally treated as a supply of service, not a sale of land. Schedule II of the Act specifically classifies the grant of the right to use immovable property for consideration as a supply of services. Assignment of Leasehold rights do not amount to ownership; they merely provide the transferee with the right to use the property for a defined period under specified conditions. Therefore, equating such assignments with the outright sale of land, which is excluded from GST under Entry 5 of Schedule III, may be a misapplication of the law.

Furthermore, the legislative intent behind GST is to create a broad and uniform tax base encompassing most forms of economic activity, including transfers of rights and interests in immovable property for consideration. The assignment of leasehold rights, especially when long-term and against substantial consideration, often functions as a de facto transfer of property for practical purposes. Ignoring the economic substance of such transactions in favour of a narrow legal interpretation could create loopholes and revenue loss for the exchequer.

The following Advance Ruling Authorities (AARs) and circulars from the CBIC have confirmed that assignments of leasehold rights are taxable under GST.

1. Maharastra Authority for Advance Ruling in the case of M/s.General Motors India Private Limited vide Ref.No.GST-ARA-31/23-24/2024-25/B-111, Mumbai, dated 10.3.2025

2. Uttara Pradesh Authority for Advance Ruling in the case of M/s. Remarkable Industries Private Limited, Noida vide Ref. no. UP ADRG 41/2023, dated 7.12.2023.

3. West Bengal Authority for Advance Ruling in the case of M/s Enfield Apparels Private Limited vide 11/WBAAR/2020-21, dated 17.8.2020.

4. CBIC Circular No. 44/18/2018-CGST, dated 2.5.2018.

In view of the above, we hold that the assignment of leasehold rights of lease land is covered by the scope of supply for levy of Goods and Service Tax under 7 of the Central Goods and Services Tax Act, 2017 and hence GST is applicable on the consideration of Transfer of Leasehold land paid by India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor).

2. Whether Recovery of Cost of Land Development and related other cost is the supply of Service for levy of Goods and Service tax under definition of Section 7 of Goods and Service tax Act, 2017 If so whether Goods and Service Tax is applicable on Recovery of cost of land Development paid India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

Unlike the leasehold rights which pertain to immovable property, the infrastructural developments such as laying roads, constructing compound walls, providing utilities, etc., involve active rendering of services and result in tangible improvements. These are separately valued and reimbursed. As per Para 5(b) of Schedule II of the CGST Act, construction of a building or civil structure intended for sale, wholly or partly, constitutes a supply of service. Furthermore, CBIC Circular No. 177/09/2022-GST dated 03.08.2022 clarifies that activities involving land development, levelling, laying of drainage, or any civil works are taxable services under GST. Hence, the related civil development work undertaken by the applicant and reimbursed by the transferee qualifies as a taxable supply of service and attracts GST at the appropriate rate.

3. Whether Kobelco Construction Equipment India Pvt Ltd is entitled to Input Tax Credit of Goods and Service tax paid on the commission to be paid in relation of the transfer of leasehold land to Sri City Development Authority, under the provision of Goods and Service Tax Act 2017?

The provisions relating to availment of Input Tax Credit under the Goods and Service Tax are extracted hereunder:

“ Section 16. Eligibility and conditions for taking input tax credit.-

(1) Every registered person shall, subject to such conditions and restrictions as may be prescribed and in the manner specified in section 49, be entitled to take credit of input tax charged on any supply of goods or services or both to him which are used or intended to be used in the course or furtherance of his business and the said amount shall be credited to the electronic credit ledger of such person.

The transfer fee charged by the Sri City Private Limited is in the nature of a consideration for tolerating an act that the applicant is otherwise refrained from doing in terms of clause 4(z) of the Lease Deed dated 29.5.2015. It is also a service classifiable under “Other miscellaneous service‟ (SAC 999794) and taxable @ 18% under Sl No. 35 of the Rate Notification. It is the consideration payable to the lessor for providing a service in the course or furtherance of business, more specifically because business includes supply or acquisition of goods or services in connection with the business in terms of section 2 (17) (d) of the GST Act. The GST to be paid on such transfer fee is, therefore, admissible as input tax credit.

In light of the above discussion, this Authority issues the following ruling:

RULING

(Under Section 98 of Central Goods and Services Tax Act, 2017 and the Andhra Pradesh Goods and Services Tax Act, 2017)

Question: Whether assignment of leasehold rights of leasehold land would be covered by the scope of supply for levy of Goods and Service tax under Section 7 of Central Goods and Services Tax Act, 2017 ? if so whether Goods and Service Tax is applicable on the consideration of Transfer of Leasehold land paid by India Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

Answer : Yes.Goods and Service Tax is applicable.

Question : Whether Recovery of Cost of Land Development and related other cost is the supply of Service for levy of Goods and Service tax under definition of Section 7 of Goods and Service tax Act, 2017 If so whether Goods and Service Tax is applicable on Recovery of cost of land Development paid Indian Metal One Steel Plate Processing Private Limited (Transferee) to Kobelco Construction Equipment India Pvt Ltd (Transferor)?

Answer : Yes. Goods and Service Tax is applicable.

Question: Whether Kobelco Construction Equipment India • Pvt Ltd is entitled to Input Tax Credit of Goods and Service tax paid on the commission to be paid in relation of the transfer of leasehold land to Sri City Development Authority, under the provision of Goods and Service tax Act 2017?

Answer : Yes