Sunshine Builders Pvt. Ltd. launched a residential project named Green Valley Residency in 2023 comprising 120 apartments on 2,000 sq. meters of land. The promoter started advertising the project through brochures and on

Sunshine Builders Pvt. Ltd. launched a residential project named Green Valley Residency in 2023 comprising 120 apartments on 2,000 sq. meters of land. The promoter started advertising the project through brochures and online portals, promising possession within 24 months and highlighting amenities such as a clubhouse and landscaped gardens. The promoter accepted booking amounts up to 20% of the apartment cost from several buyers without executing a registered agreement for sale. Some buyers paid advances based solely on the advertisement and model flat displayed at the site office. Sunshine Builders applied for registration of the project before the Real Estate Regulatory Authority (RERA) but failed to disclose certain pending litigation relating to the title of the land. The Authority did not communicate approval or rejection within 30 days. Meanwhile, the promoter continued construction and marketing activities. After two years, the project remained incomplete and possession was delayed by 12 months beyond the promised date. Further, certain promised amenities were not constructed. Devendra, an allottee, decides to withdraw and seek refund, while another allottee, Surendra, wants possession along with compensation for delay. The promoter has also neither executed conveyance deeds nor handed over the common areas despite obtaining the occupancy certificate. Aggrieved allottees have now approached RERA seeking relief. Based on above facts, answer the following under the Real Estate (Regulation and Development) Act, 2016: Is booking amount up to 20% of the apartment cost valid? Give reason.