GST on developed land sale not applicable where only common amenities are provided and no separate development service is supplied.

Sale of developed land was treated as outside GST because land remains excluded from tax as neither goods nor services, even where common amenities such as drainage, water lines, electricity lines, levelling, roads and street lights have been provided. The development works did not amount to a separate taxable supply to the plot purchaser, and the land retained its character as land in both popular and legal sense. The completion certificate concept was held relevant to construction of buildings or complexes, not to development of land. On these facts, GST was not applicable on the sale of the developed plot, and the remaining issues became redundant.

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Issues: Whether GST is leviable on sale of developed plot of land where the development is limited to common amenities and no advance is taken for further development activity.

Analysis: Land, by itself, is excluded from GST by virtue of the statutory scheme that treats sale of land as neither a supply of goods nor a supply of services. The development activity described in the case related only to common amenities such as drainage, water line, electricity line, land levelling, road and street light, which did not transfer as a separate subject of sale to the plot purchaser. The land, even if developed, retained its character as land in popular and legal sense. The concept of completion certificate was held to be relevant to construction of buildings or complexes and not to development of land. Treating such developed land sale as a taxable supply would also lead to an impermissible and absurd consequence.

Conclusion: GST is not applicable on the sale of developed land on the facts considered.

Final Conclusion: The transaction remained outside the scope of taxable supply under the GST law, and the remaining questions became redundant once the main issue was answered.

Ratio Decidendi: Sale of developed land, where only common amenities are provided and no separate development service is supplied after sale, does not constitute a taxable supply under GST.

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