Filing GSTR-1 and 3B as a tour operator: table by table

Every month you file GSTR-1 and GSTR-3B for the same set of invoices, and every month someone on your team asks the same question: does this booking go in Table 4 or Table 7? The honest answer is that GSTR-1's tables aren't arbitrary buckets. They map cleanly onto the shape of a tour operator's actual sales, once you know the split.

Get the split wrong and the damage isn't just a wrong table. A B2C booking reported as B2B skips the invoice-wise trail a scrutiny officer expects. A cancelled departure's credit note filed a week past the statutory cutoff means that tax is gone for good, not adjustable, not refundable through the return. A pure agent recovery folded into your taxable turnover inflates the number your CA has to explain every March.

This post walks GSTR-1 table by table, then GSTR-3B, for a business that sells B2B packages to other agents, B2C packages to travellers, occasionally bills a foreign client for an inbound tour, cancels departures, and pays a transporter or cab operator under reverse charge. Keep it next to your return on filing day.

Where a B2B package invoice actually lands: Table 4, not Table 5

Any invoice you raise to a GST-registered recipient goes in Table 4 of GSTR-1, regardless of the invoice value. This covers every sale to another travel agent, a corporate client with a GSTIN, or a UIN holder, whether the package is ₹8,000 or ₹8 lakh. Value never decides Table 4 eligibility. Registration status of the buyer does.

Table 4 itself has three rows. 4A carries ordinary B2B sales, the ones you invoice and collect GST on directly. 4B is for supplies where the recipient pays tax under reverse charge instead of you, which is rare on the outward side for most tour operators but exists for specific notified services. 4C covers sales made through an e-commerce operator that collects TCS on your behalf, relevant if you list packages on a marketplace that deducts tax at source.

The mistake operators make is treating "B2B" as a size category, assuming a small package sold to a small sub-agent belongs with the B2C consolidated numbers because the amount looks retail. It doesn't. If the buyer holds a GSTIN, that invoice is B2B, full stop, and it goes in Table 4 with the buyer's GSTIN attached. Selling a package to another agent carries its own margin and double-taxation traps worth understanding on their own, since GST can stack in ways a first-time seller doesn't expect.

B2C large vs B2C small: the ₹2.5 lakh line that decides Table 5 or Table 7

An invoice to an unregistered traveller goes invoice-wise in Table 5 only if it's inter-state and worth more than ₹2,50,000. Every other B2C sale, intra-state at any value, or inter-state up to ₹2,50,000, gets reported as a single consolidated figure by state and tax rate in Table 7. Get the cutoff wrong and a high-value booking either goes missing from the invoice-wise trail scrutiny expects, or clutters Table 7 with a figure that should have carried a client name.

The two tables serve different purposes. Table 5 exists for invoice-wise reporting of large inter-state B2C sales, and Table 7 is a state-wise, rate-wise consolidated total covering everything else, split between intra-state (7A) and inter-state up to the threshold (7B). "Inter-state" here means your agency's registered state differs from the place of supply, which for most domestic tour packages is the destination state where the trip is delivered, not the client's billing address. Confirm the place-of-supply logic that decides IGST or CGST for your specific package structure with your CA if that distinction isn't obvious in your invoicing.

Example: Your Mumbai-registered agency sells a ₹3,20,000 Bhutan package to an unregistered traveller based in Delhi, with the place of supply treated as inter-state to your Maharashtra registration. That single invoice crosses ₹2,50,000, so it's reported invoice-wise in Table 5. The same month, you sell a ₹45,000 Goa weekend package to another unregistered Mumbai client, intra-state and well under the threshold. That one is folded into the consolidated Table 7 figure for the period, not listed separately.

An inbound tour billed to a foreign client: why it usually isn't in Table 6

Getting paid in dollars or euros by a foreign client doesn't automatically make an inbound tour an export of service. Table 6 of GSTR-1 covers zero-rated exports and deemed exports specifically, and qualifying for that treatment depends on where the service is actually performed, not on who pays or in what currency.

A tour operator running an inbound itinerary, hotels, transport, guides, entries, all delivered inside India, is generally supplying a service whose place of supply is India. The traveller or the foreign agent booking on their behalf being located overseas doesn't shift that. Most billings to a foreign DMC or overseas agent for an inbound Indian tour are, on that logic, ordinary domestic taxable supplies at the applicable rate, reported like any other B2B or B2C sale depending on whether the foreign party holds an Indian GSTIN, not export sales sitting in Table 6.

Careful: Place-of-supply rules for cross-border service bundles get genuinely complicated, and there are structures under which part of an inbound arrangement can qualify differently. Don't self-assess this from a blog post. Get case-by-case sign-off from your CA before treating any inbound billing as zero-rated, and read the full mechanics of billing foreign clients for inbound tours before you invoice the next one.

Cancelling a departure: which table takes the credit note, and the cutoff that kills it

A cancelled booking needs a credit note, and which table it lands in depends on how the original sale was reported. For a B2B invoice (Table 4) or a B2C large invoice (Table 5), issue a formal credit note against that specific invoice number and report it in Table 9B, tied to the original document. For a B2C small sale that was only ever part of a consolidated Table 7 figure, there's no individual invoice to credit against: if the cancellation happens in the same filing period as the sale, simply net it out of that period's Table 7 total before you file. If the sale was already reported in a prior period's return, correct it through Table 10, the dedicated amendment table for earlier-period Table 7 figures.

The part that actually costs money is the deadline. Section 34(2) of the CGST Act ties a credit note's validity to a statutory cutoff measured against the end of the financial year in which the original sale happened, or the date you file your annual return, whichever comes first. As of August 2026, that cutoff is widely reported by tax practitioners to fall around 30 November following the year-end, but confirm the exact current date with your CA before you rely on it. Miss it, and the credit note can't be used to reduce your output tax at all. The tax you collected and paid on a booking that never travelled stays paid.

Careful: A departure cancelled in April for a booking sold the previous January is still well inside the window. One cancelled in October for a booking from two financial years back may already be past it. Check the original invoice date against the cutoff before you promise a client their GST portion back, since the mechanics of what happens to GST and TCS on a cancelled booking are worth reading in full before you write that promise into a refund policy.

Pure agent recoveries: the rupees that never enter GSTR-1 at all

Money you pay to a third party on a client's behalf and recover at exact cost, with no markup, doesn't enter your taxable turnover or any GSTR-1 table. Rule 33 of the CGST Rules sets three conditions for that exclusion: you made the payment on the recipient's express authorisation, you show it as a separate line on your own invoice, and the procurement is in addition to (not part of) the service you supply on your own account. It also defines a pure agent as someone who has a contractual understanding to incur the cost, never intends to hold title to what's procured, doesn't use it for their own benefit, and recovers only the actual amount spent, on top of their own fee.

A monument entry fee, a visa fee paid to VFS, a museum ticket passed through at face value: these are the everyday examples. That's the most common place agents get the split wrong on visa fees specifically, and the same logic applies to any at-cost recovery on a package.

Fail any one of the three conditions, add even a small rounding markup, skip the separate line, and the whole amount stops being a pure agent recovery. It becomes ordinary taxable value, taxed in full and reported in whichever table your buyer's registration status dictates. A cost that should never have touched your turnover figure now inflates it, and that inflated figure is what your CA reconciles against your bank credits every year.

GSTR-3B: the row that carries your 5% no-ITC output

Standard-rated tour operator output at the common 5% (no-ITC) slab sits in Table 3.1(a) of GSTR-3B, "Outward taxable supplies (other than zero rated, nil rated and exempted)". This is where most operators' entire month of package sales lands, separate from 3.1(b) zero-rated exports, 3.1(c) nil-rated or exempt supplies, and 3.1(e) non-GST supplies (fuel, alcohol and the like, if you sell anything that falls outside GST at all).

The discipline worth building into your monthly close is a simple tie-out: the taxable value you report in 3.1(a) for the period should equal the sum of what you've already reported across GSTR-1's Tables 4, 5 and 7 for the same period. If those two numbers don't match, one of the two returns has a table-classification error sitting in it, and it's far cheaper to find that mismatch yourself before filing than to have a scrutiny notice find it for you months later.

Reverse charge on cabs and GTA bills: declare it, pay it in cash, then claim it

Reverse charge on a transporter or cab bill is a three-step mechanic, not a single line item: declare the liability, pay it from your cash ledger, then separately claim it back as credit if you're eligible. First, report the RCM-liable inward supply in Table 3.1(d), "Inward supplies (liable to reverse charge)". Second, pay that liability entirely from your cash ledger. It cannot be adjusted against input tax credit you're holding, even if the credit balance sitting in your ledger would easily cover it. Third, if the inward supply is otherwise eligible for credit, claim it separately as ITC in Table 4, row A(3), "Inward supplies liable to reverse charge", which is a distinct row from your normal purchase ITC.

The two everyday triggers for a tour operator are a Goods Transport Agency (GTA) that doesn't itself charge GST on the consignment note, and a non-body-corporate cab operator supplying a rent-a-cab service to a body corporate. Both are common on the inward side of a group departure, a bus contracted for a hill circuit, a fleet of cabs for airport transfers, and both can go unreported if your accounts team only watches outward invoices for GST. The rates and eligibility conditions change often enough (confirm the current position as of August 2026) that they deserve their own read: see the full breakdown of when your travel agency owes reverse charge before you set up your vendor bills.

The GSTR-2B reconciliation and the notices operators are getting

A mismatch between the input tax credit you claim in GSTR-3B and what shows up in your auto-drafted GSTR-2B can happen even when you've done nothing wrong. If a vendor, a hotel, a transporter, a DMC, files their own GSTR-1 late, their invoice simply hasn't reached your 2B yet for that period, but you've already claimed the credit based on the physical bill in hand. The portal compares the two figures, and a gap above a certain size now commonly triggers a system-generated mismatch intimation asking you to explain or reverse the difference before you can move forward cleanly on a later filing.

This is catching more operators than deliberate tax evasion ever did, because supplier-side delays are entirely outside your control. The practical discipline is reconciling 2B against your claimed ITC every month, not just at year-end, and keeping a simple log of which credits are pending a late-filing vendor versus genuinely wrong. The exact current threshold and response window for this intimation move with CBIC circulars (as of August 2026), so confirm the specifics with your CA the first time you see one rather than guessing at the deadline. The mechanics of how the matching system itself works are worth understanding properly, not just the notice that follows a mismatch.

The month-end checklist: five errors that get travel agencies noticed

• Reconcile GSTR-1 plus GSTR-3B turnover for the period against your Form 26AS/AIS figures before you file, not after a mismatch notice arrives.
• Confirm every credit note for a cancelled or amended booking is filed before the statutory cutoff tied to the original invoice's financial year, not left "for next month."
• Verify RCM liability on GTA and rent-a-cab bills was actually paid from the cash ledger, not just declared in 3.1(d) and left unpaid, before you submit the return.
• Check that no B2B invoice (any registered-recipient sale, regardless of value) has been folded into the Table 7 consolidated B2C figure by mistake.
• Confirm pure agent recoveries (visa fees, entry tickets, monument fees) are shown as separate at-cost lines on the invoice, not bundled into your taxable service value.

Common questions

What GST rate does a tour operator charge?

Most Indian tour operators invoice packages at 5% GST without input tax credit, though an 18%-with-ITC option exists depending on how the supply is structured and billed. Which slab applies to a specific invoice line depends on the service composition, and it's worth working through against your own package structure rather than assuming one rate covers everything you sell.

Are tour operator services taxable under GST?

Yes. Tour operator and travel agency services are ordinary taxable supplies under GST, with no blanket exemption for the trade. The only amounts that fall outside taxable turnover are genuine pure agent recoveries meeting Rule 33's conditions and, in narrow cases, qualifying zero-rated exports.

Do I still need to file a GST annual return separately from GSTR-1 and 3B?

GSTR-1 and GSTR-3B are your monthly or quarterly returns; most registered businesses, tour operators included, also have a separate annual return obligation on top of these, with its own form and deadline. Treat it as a distinct filing on your compliance calendar, not something GSTR-3B substitutes for, and confirm your specific threshold and applicability with your CA.

What HSN or SAC code should a tour operator use?

Tour operator and travel-related services are classified under specific Services Accounting Codes (SAC), not goods HSN codes, and the correct code depends on exactly what you're billing, a package, a standalone visa service, ticketing. Get the precise code for each of your invoice line types confirmed with your CA or GST software provider rather than reusing one code across every kind of sale.

The short version

• A B2B invoice (any GST-registered buyer) always goes in Table 4, whatever its value. Table 5 is for invoice-wise B2C sales above ₹2,50,000 inter-state; Table 7 consolidates everything else.
• An inbound tour billed to a foreign client is usually an ordinary domestic taxable supply, not a Table 6 export, unless place-of-supply rules genuinely put it there. Get that call checked by a CA.
• Credit notes for cancelled B2B/B2C-large invoices go in Table 9B against the original invoice; consolidated B2C corrections go through Table 10 if reported in a prior period. Miss the statutory cutoff and the tax stays paid.
• Genuine pure agent recoveries under Rule 33 (exact cost, separate line, client authorisation) never enter your taxable turnover or any GSTR-1 table at all.
• In GSTR-3B, 5% no-ITC output sits in Table 3.1(a); tie that figure back to GSTR-1's Tables 4+5+7 for the same period every month.
• Reverse charge on GTA and cab bills is declared in 3.1(d), paid in cash (never adjusted against available ITC), then claimed back separately in Table 4 row A(3) if eligible.
• Reconcile GSTR-2B against claimed ITC monthly. A mismatch often means a vendor filed late, not that you did anything wrong, but the intimation still needs a timely response.