GSTR-9 for a travel agency: where each kind of sale goes
GSTR-9 for FY 2025-26 is due 31 December 2026. A table map for where your 5% packages, 18% fees, advances and pure-agent amounts actually go.
Khardung La · 05:50Your CA calls in December asking for the GSTR-9 numbers, split by rate and by buyer. For an agency that sold 5% packages, charged 18% fees on air tickets and visas, passed through airline fares and embassy costs, took advances, and cancelled a Gulf group along the way, that call turns into hours of digging through invoices nobody ever mapped to an annual return. GSTR-9 for a travel agency is mostly a sorting problem, not a calculation one.
GSTR-9 for FY 2025-26 is due on 31 December 2026, under Rule 80(1) of the CGST Rules. The deadline that actually costs you money, though, lands a month earlier, on 30 November, or on your filing date if that's sooner. This post maps every kind of travel sale to its GSTR-9 row, packages, fees, pure-agent amounts, advances and credit notes, then works through one agency's numbers.
Who must file GSTR-9 for FY 2025-26
Only if your agency's aggregate turnover crossed ₹2 crore in FY 2025-26. Notification No. 15/2025-Central Tax exempts anyone up to that figure, a standing exemption from FY 2024-25 onward. Cross ₹5 crore and you also file GSTR-9C, a self-certified reconciliation against audited financials, by the same date under Rule 80(3). Section 44 requires every registered person, except an ISD, a GST TDS/TCS deductor, or a casual/non-resident taxable person, to file an annual return, and bars filing one three years past its due date: FY 2025-26's return closes after 31 December 2029 unless notified otherwise.
Aggregate turnover, under Section 2(6), is the value of your own supplies, not whatever lands in your bank account. An amount genuinely meeting every Rule 33 pure-agent condition, authorised, separately invoiced, exact cost, sits outside this calculation; that's a CA call, not a blanket rule. Two GSTINs under one PAN add up for both tests.
Careful: A year of ticketing and hotel pass-throughs makes your bank balance look bigger than your turnover. Run the ₹2 crore test on what you actually sold, not on gross receipts.
30 November comes first, not 31 December
Three cut-offs land on 30 November 2026, or your GSTR-9 filing date if earlier: the last date to claim ITC on an FY 2025-26 invoice under Section 16(4), to fix a GSTR-1 entry (Section 37(3) proviso), and to fix a GSTR-3B entry (Section 39(9) proviso). Credit notes for FY 2025-26 supplies follow the same date under Section 34(2).
By the time you sit down to file the annual return in December, these windows are shut. GSTR-9 cannot pull in a missed credit or fix a wrong GSTR-1 line; those only happen in the monthly GSTR-1 and GSTR-3B returns you already file. Filing GSTR-9 earlier than 30 November doesn't buy safety either, it brings the cut-off forward to your filing date.
Since 1 October 2025, a credit note only reduces your output tax if a registered buyer who took ITC on the invoice has reversed it, or, for any other buyer, if the tax hasn't been passed on to someone else, which in practice usually means refunding it to the client. Issuing the note alone no longer does the job.
The table map: where each kind of travel sale goes
Nearly every taxed domestic travel sale lands in one of two outward-supply rows by who bought it, not by its rate: Table 4A for unregistered travellers, Table 4B for anyone with a GSTIN. Advances, credit notes and late invoices each get their own row, per the GSTR-9 instructions as amended by Notification 13/2025-Central Tax.
| What you sold or did in FY 2025-26 | GSTR-9 row | Source | Watch out |
|---|---|---|---|
| 5% package to an unregistered traveller | 4A (net of credit notes) | GSTR-1 Tables 5, 7, 9, 10 | Above ₹1 lakh inter-State is Table 5, not 7 |
| 5% package to a corporate or sub-agent with GSTIN | 4B | GSTR-1 Table 4A | The buyer's GSTIN decides, not the value |
| 18% air/visa fee to a traveller | 4A | GSTR-1 Tables 5/7 | Fee only, or Rule 32(3) deemed value, never the fare |
| 18% fee/commission billed to a corporate, hotel or portal | 4B | GSTR-1 Table 4A | Same row as 5% B2B packages |
| Advance by 31 Mar 2026, no invoice yet (Apr-May departure) | 4F | GSTR-1 Table 11A | Only advances still unadjusted at year-end; counts in 5N |
| Credit note to a GSTIN holder, issued in the FY | 4I | GSTR-1 Table 9B | From 1 Oct 2025 buyer must reverse any ITC taken |
| Credit note on a B2C sale, issued in the FY | inside 4A (netted) | GSTR-1 9B / Table 7 | No separate 4I line |
| Credit note issued Apr-Oct 2026 on an FY 2025-26 sale | Table 11 | GSTR-1/1A/IFF by 30 Nov | After 30 Nov it reduces nothing |
| FY 2025-26 sale invoiced late in Apr-Oct 2026 | Table 10 (tax in 14) | GSTR-1 Apr-Oct 2026 | Pay with interest |
| Visa/VFS fee at cost; airline fare passed through | 5F "no supply", or not reported | GSTR-1 Table 8 if reported | CA call; must match books and 3B |
| Reverse-charge purchase (e.g. import of services, GTA) | 4G; ITC in 6C/6D/6F | GSTR-3B 3.1(d), 4A(2)/(3) | Paid in cash |
| ITC on 18% inputs for the year | 6B (6A1 = FY24-25 credit claimed Apr-Oct 25) | GSTR-3B 4A(5) | 6J should ideally be zero |
| Common ITC reversed for 5% packages | 7C (Rule 42) | GSTR-3B 4B | True-up with the September return |
| Supplier GST in GSTR-2B you couldn't use | 8A vs 8B, explained in 8E/8F | GSTR-2B Table 3(I) | Lapses in 8K; an officer's first question |
| FY 2025-26 ITC claimed in Apr-Oct 2026 returns | 8C and 13 | GSTR-3B 4A, Apr-Oct 26 | Only counts to 30 Nov 2026 |
| FY 2025-26 ITC reversed in Apr-Oct 2026 returns | 12 | GSTR-3B 4B, next FY | Not part of Table 7 |
Packages at 5%, fees at 18%: same two rows, split by the buyer
A 5% package invoice and an 18% service-fee invoice land in the same row if the buyer's registration status matches: Table 4A from GSTR-1 Tables 5 and 7 (plus amendments in 9 and 10), Table 4B from GSTR-1 Table 4A. The invoice's rate doesn't decide the row; the buyer's GSTIN does.
Inside GSTR-1 itself, an inter-State B2C invoice above ₹1,00,000 goes to Table 5 and smaller ones to Table 7B, a threshold cut from ₹2.5 lakh to ₹1 lakh on 1 August 2024 under Notification 12/2024-Central Tax. Both roll up into the same 4A regardless, so this only changes monthly filing, not the annual figure.
If you use the optional deemed-value method under Rule 32 instead of your actual fee or commission, the value reported is 5% of the basic fare for domestic tickets and 10% for international, taxed at 18%. Fee or deemed value, the figure still lands in 4A or 4B by who bought it.
Air fares and visa fees you passed through: Table 5F, or nowhere
Whether the airline fare and embassy fee you recovered at exact cost show up anywhere on GSTR-9 is genuinely contested among practitioners, and it turns on whether you actually meet Rule 33, not a blanket rule for travel agents. Rule 33 excludes a pure agent's pass-through cost from value of supply only where payment was authorised by the client, the amount sits on a separate invoice line, and it accompanies a service billed on your own account, with no title taken, no markup, exact-cost recovery only.
GSTR-9's instructions say "no supply" belongs under 5F, sourced from GSTR-1 Table 8. Whether Rule-33-compliant fares and visa recoveries count as that "no supply", or shouldn't appear at all, is where practitioners split. Either reading changes reported 5N turnover, not tax payable.
Pick one position, keep it consistent with GSTR-1 Table 8, GSTR-3B 3.1 and your books, and confirm it with your CA before filing. The invoice-line mechanics behind the test are in how the pure-agent rule works for visa fees.
Advances and cancellations: Tables 4F, 4I and Table 11
An advance you taxed but hadn't invoiced by 31 March 2026 sits in Table 4F, which the instructions say may be filled from GSTR-1 Table 11A; only advances still unadjusted at year-end belong there. A cancellation credit note to an unregistered client issued before year-end nets straight into 4A. A credit note to a GSTIN holder issued within FY 2025-26 gets its own line in 4I, though it only reduces your tax if the recipient reverses any ITC it took on the invoice.
A credit note issued in April to October 2026 against an FY 2025-26 sale skips 4I entirely and goes into Table 11 in Part V, which Notification 13/2025-Central Tax reworked from FY 2024-25 to pick up credit notes in your GSTR-1/1A/IFF for April to October of the next year, filed by 30 November; miss that and the note reduces nothing. The receipt-voucher mechanics behind Table 4F are in GST on booking advances for tour operators.
The ITC half: 8A, 6A2 and why the gap is normal for a 5% operator
Sell mostly 5% packages and GSTR-9 will almost always show more ITC in Table 8A than you actually claimed in Table 6B. That gap is expected, not an error: the 5% package rate comes with a no-ITC condition, so much of that credit was never yours to claim.
Table 8A auto-populates from GSTR-2B Table 3(I) for FY 2023-24 onward, even though its label still reads "ITC as per GSTR-2A". For FY 2025-26, that means each month's GSTR-2B as your IMS actions shaped it: accepting, rejecting or leaving a supplier invoice pending changes what lands in the return.
Notification 13/2025-Central Tax reworked the ITC tables for FY 2024-25 onward: 6A1 carries FY 2024-25 credit claimed in April-October 2025 returns, 6A2 is the net ITC belonging to FY 2025-26 (6A minus 6A1), and 6J checks 6A2 against 6B to 6H. The gap widens further because common credit (rent, software, phones) used partly for 5% packages is reversed under Rule 42, in Table 7C, as if that share were exempt. An unclaimed or reversed invoice in your 2B isn't a mismatch to chase, it's the mechanism working as intended.
What the September 2025 rate change touched, and what it left alone
Tour-package pricing stayed put: a package billed inclusive of accommodation and transport is still 5% without ITC, apart from a limited credit for services bought in the same line of business, under the same serial 23 of Notification 11/2017-Central Tax (Rate), untouched by the September 2025 changes. What did move, from 22 September 2025: hotel rooms up to ₹7,500 a day dropped from 12% with ITC to 5% without; a vehicle rented with an operator lost its 12%-with-ITC option, becoming 18% (the 5% no-ITC option stayed); and non-economy air moved from 12% to 18%, under Notification 15/2025-Central Tax (Rate).
For a booking straddling 22 September, Section 14 decides the rate: broadly, it follows whichever side of the change two of the three events (service, invoice, payment) fall on, not whichever suits the quote. A few relaxations (combining exempt and nil-rated in 5D, net-of-credit-notes 5A-5F, leaving Tables 15 to 18 blank) stop at FY 2024-25 in the instructions as published; no FY 2025-26 extension had appeared on CBIC's notification list as of October 2026, so check the current portal form before assuming last year's shortcuts carry over.
A worked agency: packages, fees and the late fee
Say a single-GSTIN agency in one State sells packages as principal at 5%, charges 18% fees on air tickets and visas, and earns 18% commission from hotels and portals. Here's how its FY 2025-26 maps onto GSTR-9.
| What happened in FY 2025-26 | Amount | GSTR-9 field |
|---|---|---|
| B2C package sales (5%), net of ₹6,00,000 in-year cancellation credit notes | ₹1,72,00,000 | 4A |
| 18% fees billed to unregistered clients (air + visa) | ₹5,40,000 | 4A |
| B2B package sales (5%) to corporates and sub-agents | ₹38,00,000 | 4B |
| 18% fees/commissions billed to registered parties | ₹6,60,000 | 4B |
| Advances for April-May 2026 departures, uninvoiced by 31 March | ₹14,00,000 | 4F |
| B2B credit note: a Gulf group cancelled March 2026 | (₹4,00,000) | 4I |
4A, 4B and 4F sum to a gross outward figure (4H) of ₹2,36,00,000, tax ₹13,36,000. Net the Gulf credit note (4I) and 4N lands at ₹2,32,00,000, tax ₹13,16,000.
Strip out the uninvoiced advance and actual taxable supply is ₹2,18,00,000: above ₹2 crore, so GSTR-9 is mandatory; under ₹5 crore, so no GSTR-9C. Another ₹1,52,00,000 of fares and visa fees moved through the bank at exact cost, which isn't the number either test uses.
Example: Reported as "no supply" in 5F, the ₹1,52,00,000 of pass-throughs push 5N to ₹3,84,00,000. Left off entirely, 5N reads ₹2,32,00,000. Either way, tax payable is unchanged.
Rule 42 reversal on common credit of ₹1,44,000 works out to about ₹1,36,000 reversed, using exempt value E of ₹2,06,00,000 against turnover F of ₹2,18,00,000 (about 94.5%); including advances moves it only slightly, with the CA finalising it. Filed 30 days late, the late fee is 30 x ₹50 a day = ₹1,500, well under the cap of 0.04% of State turnover (roughly ₹9,000 for this agency), which takes about six months of delay to reach.
The late fee, and what you cannot undo after filing
For most agencies, the late fee for a delayed GSTR-9 is far smaller than the ₹200-a-day figure that circulates online. Under Notification 07/2023-Central Tax, the fee up to ₹5 crore aggregate turnover is ₹25 CGST plus ₹25 SGST a day, capped at 0.02% plus 0.02% of State turnover; between ₹5 crore and ₹20 crore it is ₹50 plus ₹50 a day under the same cap. Only above ₹20 crore does the full Section 47(2) fee apply: ₹100 plus ₹100 a day, capped at 0.25% plus 0.25%.
There's no revision window after filing; neither Section 44 nor Rule 80 lets you amend a filed GSTR-9. If filing uncovers tax you still owe, the form routes payment through Form DRC-03, from your cash or credit ledger, though the instruction letting you declare extra liability inside GSTR-9 currently names years only up to FY 2024-25; check it for FY 2025-26.
What's still moving: the 57th Council recommendations
A clutch of GSTR-9-adjacent changes were only recommended, not notified, as of October 2026, so none of this applies to your FY 2025-26 filing yet. At its 57th meeting on 8 October 2026, the Council recommended amending Sections 16, 37 and 39 to align the GSTR-1 and GSTR-3B provisions with the Section 16(4) ITC time limit, a proposed Rule 60(6A) writing IMS accept, reject and pending actions into the rules, an Electronic Credit Reversal and Reclaim Statement under a proposed Rule 86C, an in-principle nod to a quarterly-payment scheme for B2C-only taxpayers up to ₹5 crore, and a GSTR-3B late-fee waiver for taxpayers up to ₹5 crore who file by the end of the month it was due. Each needs a notification or a law amendment first, and none has issued as of this writing. Check CBIC's list again before filing in December; the gap between a recommendation and a notified rule has sometimes run months.
Common questions
Is GSTR-9 compulsory for every GST-registered travel agency?
No. Notification 15/2025-Central Tax exempts anyone up to ₹2 crore aggregate turnover, standing from FY 2024-25 onward. Above that, filing is mandatory; above ₹5 crore, GSTR-9C is added.
GSTR 9 mein pure agent ka air fare aur visa fee kahan dikhayein?
Depends on whether the recovery genuinely meets Rule 33: separate invoice line, authorisation, exact cost, no markup. If it does, the debate is 5F as "no supply" versus not reporting it at all; tax payable is the same either way. Confirm with your CA.
Can I claim ITC I missed for FY 2025-26 in GSTR-9?
No. The last date is 30 November 2026, or your filing date if earlier, under Section 16(4). GSTR-9 cannot pull in a credit never claimed in a GSTR-3B.
Do I need GSTR-9C as well?
Only above ₹5 crore aggregate turnover, under Rule 80(3). Below that, GSTR-9 alone is enough, whether filing is mandatory or by choice.
GSTR 9 ki last date miss ho gayi to kya hoga?
A late fee applies from 1 January 2027: ₹25 CGST plus ₹25 SGST a day up to ₹5 crore turnover, capped at 0.04% of State turnover. It stops growing once you hit that cap.
The short version
- GSTR-9 for FY 2025-26 is due 31 December 2026 under Rule 80(1); no extension is notified as of October 2026.
- Up to ₹2 crore aggregate turnover you're exempt from filing (Notification 15/2025-CT); above ₹5 crore, GSTR-9C is also due.
- The real deadline is 30 November 2026, or your filing date if earlier: last date for FY 2025-26 ITC, GSTR-1 and GSTR-3B fixes, and credit notes. GSTR-9 cannot claim a missed credit.
- Sort every sale by buyer, not rate: Table 4A for unregistered clients, 4B for anyone with a GSTIN.
- Pure-agent air fares and visa fees in Table 5F, or nowhere, is a CA call, not a settled rule; stay consistent with your GSTR-1 and books.
- The tour-package 5% rate didn't change on 22 September 2025; hotels up to ₹7,500, the 12% cab-rental option, and non-economy air did.
- No revising GSTR-9 after filing, and the late fee is ₹25 plus ₹25 a day up to ₹5 crore turnover, not the ₹200-a-day figure online.