Course Relevance:
GST Law and Practice: Calculation of GST under Dual GST model
Case Narrative:
GST 2.0 w.r.t the Mid-Range Hospitality Sector: A Quantitative Caselet
The Context of reform
In early 2026, the GST Council introduced structural reforms dividing the former 12% and 18% slabs into a single 18% standard rate, while the latter being reduced to a 40% slab for luxury/demerit goods. So this caselet looks at the implications of new GST reforms on mid-range hospitality (hotels with room tariffs ₹1,001–₹7,500/night) which has been reduced from 12% to 5% by way of the 2025 amendments without ITC.
Profile of the Industry: Mid-Range Hospitality
The mid-range segment is that at the core of India’s domestic tourism as it accounts for employment and development with respect to the economy in the region. Under the set-up in the pre-2026 format these hotels operated on a three-tier system:
| Tariff Slab | GST Rate | ITC Availability |
| ≤ ₹1,000/night | Exempt | N/A |
| ₹1,001–₹7,500/night | 12% | Allowed |
| > ₹7,500/night | 18% | Allowed |
The mid-range segment is that at the core of India’s domestic tourism as it accounts for employment and development with respect to the economy in the region. Under the set-up in the pre-2026 format these hotels operated on a three-tier system:
The 2025 reform shifted all middle tier to 5% without ITC to make it affordable for the middle class. The proposed GST 2.0 alliance to merge into a unified 18% standard rate for 2026 is an entirely different step and removes the preferential rate.
Analysis of Impact w.r.t Consumer Demand
Effects of Price Elasticity
But consumer savings are still visible with the reform that’s really going on (actual 2025). One ₹6,000 room previously cost ₹6,720 (with 12% GST), and the same room has been reduced to ₹6,300 in a 6.25% reduction as a result of the reform.
Industry estimates suggest 5–7% occupancy increases in leisure markets and 3–5% in business hubs. That results in 7–10% revenue increases for budget and mid-scale hotels.
As for that 18% unified rate, the same ₹6,000 room would cost ₹7,080—up 5.4% compared to the 5% figure for this level, which remains less than 12% back in the pre-2025 (14%) case. This creates some degree of ambiguity of demand effects:
- Positive: Rate remains below the historical 12% levels, maintaining some affordability gains.
- Negative: Rate still below historical 12% and that’s some stability or gains. • Price hikes after the 5% period may stop the demand from September 2025.
Rajesh Magow of MakeMyTrip says “the 2025 reduction in stays will make stays more affordable for a large share of Indian travellers” and “can only reinforce demand in the domestic market.”
For 18% unified rate, the risk is that it will reverse this stimulus.
Impact Analysis: Profit Margins
The margin calculation reveals the critical trade-off between rate reduction and ITC withdrawal:
Table
| Scenario | GST Rate | ITC | Effective Cost Structure |
| Pre-2025 | 12% | Yes | Lower embedded costs |
| 2025 Reform | 5% | No | Higher operational costs, lower tax outgo |
| Hypothetical 2026 (18% unified) | 18% | Yes (assumed) | Higher tax outgo, ITC recovery possible |
Under the 5% structure, hotels face “costlier operating costs” such as unrecoverable input taxes on procurement, equipment, and services. With ITC in place, the current 18% rate can increase margin protection but with high consumer prices.
Dr. Sanjay Sethi at Chalet Hotels describes the ITC withdrawal as “an unintended anomaly,” urging retention of ITC benefits even at lower rates. The implementation of the 18% unified slab can address this industry need but may fail to put in a pro-consumer business model at the table at the high price point.
One had to make allowances for changing the classification criteria.
In 2025, a new ₹7,500 cut-off point for classification systems that was simpler than earlier multi-tier classification methods made up an imbalance in pricing which led to an array of disputes in the field of classification.
Classification challenges:
1. Tariff adjustment: For hotels and spas, prices of rooms of ₹7,501 and the current rate of ₹6000 are different, that makes prices of rooms under this cut-off lower by 5% to 18% so artificial tariff clustering is recommended for hotels and spas that go up the cost and then get paid.
2. Bundled services: We do not know whether one needs food, spa or transportation services under our room tariff, with separate rates.
3. Dynamic Pricing: When revenue management systems vary rates, hotels may go over the limit every month and that, in turn, is a costly matter.
Could a 2026 merger in which 18% standard rate with 40% luxury rate not reduce classification disputes:
• Reduced disputes: elimination of the ₹7,500 key boundary is a decisive factor for several mid-range properties
• Persistent disputes: luxury (presumably >₹7,500 or more) and demerit goods category (tobacco, high-end vehicles) imply new contested boundaries
• New disputes: “Specified premises” determination for restaurants — whether any room above threshold rates is controversial
According to Deloitte’s analysis, hotels need to conduct “detailed apportionment exercises, backed by documentation and reconciliations” to cope with ITC reversal obligations under the 5% regime.
If we adopted another 18 percent rate, that would help simplify compliance for pure accommodation providers but there still remains difficulties for mixed-service establishments.
Discussion: The Policy Trade-off
The GST 2.0 slab consolidation presents a fundamental tension between administrative simplicity and targeted economic stimulus:
Table
| Objective | 5% without ITC (2025) | 18% unified with ITC (Hypothetical 2026) |
| Consumer affordability | Strong immediate benefit | Moderate benefit relative to pre-2025 |
| Industry margin protection | Weak (no ITC) | Stronger (ITC restored) |
| Compliance simplicity | Moderate (threshold monitoring) | Higher (fewer slabs) |
| Revenue neutrality | Requires volume compensation | Potentially higher collections |
The 2025 reform focused on demand stimulation from price reductions, a “pro-consumer move” for the holiday celebration.
The consolidation scenario of 2026 involves rate rationalization and revenue protection and some demand loss.
Finally, by conclusion, the simplification in the slabs makes some classification disputes easier (e.g. ₹7,500 threshold clustering) but also introduces new boundaries at the luxury/demerit goods end point. The mid-range hospitality sector shows that GST implementation faces inevitable trade-offs between consumer affordability, industry profitability, and administrative efficiency; no one structure can deliver all three simultaneously and efficiently.
Discussion Questions:
- Which approach better serves long-term sectoral growth in mid-range hospitality, and why?
- How would you redesign the classification system to minimize such boundary games while maintaining policy differentiation between budget and luxury accommodations?
- What compliance mechanisms would be necessary under either the 2025 or 2026 GST structure to handle real-time tariff fluctuations without creating prohibitive administrative burdens?
- If GST 2.0’s 40% luxury/demerit slab were extended to include “premium dining experiences” (e.g., restaurants in 5-star hotels), how might this reshape competitive dynamics between standalone restaurants and hotel-based F&B operations?








