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    <description>A joint development arrangement that required the developer to survey, level, fence and construct roads, drains and pathways, with sale proceeds shared in a fixed ratio, was treated as more than a mere sale of land. The dominant element was held to be development of land for consideration, so the transaction fell outside the exclusion for sale of land and was taxable as a supply of service under GST. The valuation accepted by the lower authority under Rule 31 of the CGST Rules was also upheld, as no infirmity was found in the method once the activity was characterised as a taxable service.</description>
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