completion certificate which had been issued was only in respect of the showrooms, food courts, gaming zones and the cinema hall, which were of no relevance to them. According to them, the corporate debtors had not even applied for the final completion certificate, as per the RTI reply dated 24.03.2018 received by them from the UPSIDA. They asserted that, as per the Rules of the UPSIDA, in the absence of a completion certificate and without the clearance of the UPSIDA, no conveyance/sublease deed could be executed or registered, and actual possession could not be delivered. They pointed out that the property in question was leasehold land and it was necessary that the UPSIDA, being the lessor, and the developer, being the lessee, confirmed the status of the allottees as sublessees, by way of tripartite sublease deeds. They relied upon their allotment letters which posited that possession could not be given without such tripartite sublease deeds. They further asserted that the developers had stopped payment of assured returns from January, 2014, though the same were to be given till final completion was accomplished and tripartite sublease deeds were executed. They, accordingly, sought initiation of insolvency proceedings against the corporate debtors. 6. Significantly, Bhasin Ltd. failed to file a reply before the NCLT. Grand Venezia Ltd., however, filed a reply claiming that it was a broker having purchase/sale rights of the entire building of which Bhasin Ltd.