GST ITC on GIDC Transfer Fees and N.U.Penalty

If sale of building was subject to GST then ITC can be claimed. Otherwise no

transfer fees and non-utlisation penatly is payable to GIDC, by buyer party on transfer of land process.  Such transfer fees + 18% GST is applicable.   

Whether ITC on such GST paid is allowable ?  Land will be Leasehold land which is given by GIDC on generally 99 years term.