Held that the assessee was only permitted by landowners to develop scheduled property as residential apartment buildings and it could not be construed as delivery or possession in terms of section 53 of Transfer of Property Act read with section 2(47)(v), as legal possession of scheduled property continued to remain with possession of landowner.  Amount received was refundable security deposit. The assessee could not be held as the assessee-in-default under section 201(1) and 201(1A) for failure to deduct tax at source. (AY. 2014-15)