Treading GST path - XLVII - GST liability of landowners under Joint Development Agreements

Sir, good article. Regarding taxability of TDR my doubt is as follows: While registering flat Builder in favour of flat buyer whether he will transfer the property rights over UDS of land either as holder of property rights or as holder of development rights? If it as holder of property rights,when he has got only development rights from LO, how can he transfer property rights over UDS of Land to the buyers of his share of flats?
I think unless such transfer of rights over UDS of land are not executed in terms of GPA, which is normally part of JDA it appears to me that right of transfer of property rights over UDS of land is through joint development agreement only , then such transfer of rights are covered under schedule III of CGST Act as sale of land which goes out of GST. Please examine

mallikarjun reddy c 31/08/2018