Details of the Order
The Company received Order-in-Appeal No. 355-360/CGST/APPEALS/GGM/LKG/2026-27 dated June 24, 2026, from the Additional Commissioner, CGST (Appeals), Gurugram, on August 06, 2026, at 03:25 P.M. (IST). This order was passed under Section 107(11) of the CGST Act, 2017 read with Section 20 of the IGST Act, 2017.
The appellate order rejected the six appeals filed by the Company against an earlier Order-in-Original dated January 31, 2025, passed by the Assistant Commissioner, Division - East – 2, Central Tax, CGST Gurugram.
Financial Impact
The upheld demand consists of:
- GST demand: ₹89,80,778
- Applicable interest: As applicable (amount not specified)
- Penalty: ₹89,80,778
Total confirmed financial liability: ₹1,79,61,556 plus applicable interest.
The Company states there is no change in the quantum from what was previously disclosed on February 05, 2025.
Period of Applicability
The order applies to the period from July 01, 2017 to March 31, 2023 (Financial Years 2017-18 to 2022-23).
Reason for Dispute
The dispute concerns the classification of services rendered by the Company to overseas entities, including Booking.com B.V., Netherlands. The tax authority contends these services constitute 'intermediary services' under Section 2(13) read with Section 13(8)(b) of the IGST Act, 2017, and are therefore taxable. The Company had classified them as 'export of services' under Section 2(6) of the IGST Act, 2017, which would be zero-rated.
Company's Stance and Next Steps
The Company believes it has a strong case on merits. It intends to file a further appeal before the Hon'ble Goods and Services Tax Appellate Tribunal within the prescribed time limit.
The Company states that aside from legal and other expenses to be incurred in contesting the matter, no material financial implications are expected, indicating it does not anticipate ultimately owing the amount.