Special leave petition dismissed while exemption under Notification No. 12 of 2017-CT (Rate) and Clause 2(a) issues remain open.

The Supreme Court dismissed the special leave petition and affirmed the High Court's view, finding no ground to take a different position. It confined its conclusion to agreement with the High Court and did not undertake fresh examination of the separate contentions raised. The Court expressly left open the questions concerning the exemption under Notification No. 12 of 2017-CT (Rate) and the scope of Clause 2(a) of Schedule II, including the expression that a licence to occupy land is a supply of services. Those issues were not adjudicated and remain available for future determination.

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Outcome: The special leave petition was dismissed, and the issues relating to the exemption under Notification No. 12 of 2017-CT (Rate) and the scope of Clause 2(a) of Schedule II were left open.

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