Explaining the financial position of Sky Light Hospitality, Khemka wrote in his report, "On the date of grant of letter of intent, the applicant company was a newly registered company with a paid up capital of just one lakh rupees and consisted of two share holders, Robert Vadra with 99 per cent ... and his mother, Maureen Vadra with one per cent. There was zero income up to March, 31, 2008. The expenditure incurred upto March 31, 2008 was Rs. 43,380 and this too was met using borrowed money. The capacity of the applicant company was nothing other than Robert Vadra. The man became the measure of everything and the entire statutory apparatus a castle of sand."

The report also elaborated how Haryana's Department of Town and Country Planning (DTCP) failed to check the authenticity of the "sham sale transaction" between Onkareshwar Properties and Sky Light Hospitality.

"Sky Light Hospitality made no payment as mentioned in the registered deed no. 4928, dated February 12, 2008 by virtue of which the company claimed legal title over the land. The sale was a complete sham ... No price was promised ..and no price paid as claimed in the registered deed," Khemka's report said. It also added how the Haryana government showed "undue haste in issuing the letter of intent (LoI) to Vadra's company in granting licence for developing a housing colony".

According to Khemka's report, LoI was issued on March 28, 2008 within 18 days of the application. A collaboration agreement was signed between Sky Light and DLF on August 5, 2008 on a non-judicial stamp paper worth Rs 100. As per the agreement, the land owner's (Sky Light) contribution was the land title and a LoI from the Haryana government and rest of the responsibility was of the developer, including obtaining commercial colony licence from DTCP, development of commercial project buildings and maintenance of assets created. The gross commercial area developed was to be shared equally between the land owner and the developer, the report said.

"The Collaboration Agreement between two parties show that there was never any intent on the part of Sky Light Hospitality to develop a colony on the said land. The land title and LoI were sham transactions routed through Sky Light Hospitality so that part of the unofficial premium .... is remitted in white by the developer, DLF Retail Developers to Sky Light Hospitality," Khemka wrote in his report to the inquiry committee.