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In the subject case we find that the applicant is only going to lease out the lands to the Municipal Corporations and there is no element of goods involved in the subject transaction. Hence we have no hesitation in considering the subject services as "pure services".

Shanti Prime Publication Pvt. Ltd.

Pure Service — The applicant is a company wholly owned and controlled by the Government of Maharashtra State is declared to be the New Town Development Authority for Navi Mumbai and entrusted with job of development thereof by the Government of Maharashtra State under provisions of the MRTP Act, 1966. The applicant would be transferring by way of lease, vacant plots of ‘Maharashtra State Government owned lands’ or ‘privately owned lands acquired under the Land Acquisition Act, 1894 by the Maharashtra State Government. Applicant sought an advance ruling on various questions and which were answered in affirmative in respect of a(iii), a(iv) and b(l) above. In respect of b(ii) and b(iii), the services will be taxable @ 18% GST under Chapter Heading 9972, Sr. No. 16, clause (iii). — City And Industrial Development Corporation of Maharashtra Limited, In Re… [2019] 11 TAXLOK.COM 079 (AAR-Maharashtra)

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