Fourteen GSTINs, no single view of what was actually captured.
The conglomerate ran travel through a global TMC of the kind every large Indian enterprise uses, and posted invoices into SAP S/4HANA across fourteen GSTINs, one per major state of operation. On paper, the system worked. Tickets were booked, invoices were issued, and a percentage of the input tax on each ticket was supposed to flow back as recoverable ITC against the corresponding GSTIN.
In practice, a meaningful share of those invoices never reached the company's tax desk in a usable form. Some came with the wrong GSTIN listed. Some arrived after the relevant return cycle had closed. Some never arrived at all, the carrier had issued them to a generic email alias that no one read. The group's internal tax team estimated leakage at three to four per cent of annual airline tax, which on ₹2,400 Cr of travel spend translated to a recovery gap of roughly thirty crore a year, year after year.
The group's finance leadership knew there was a leak. What they did not have was a way to see it in one place, or a position on which credits were genuinely irrecoverable versus which were sitting in the system waiting to be found. The firm was brought in for the diagnostic.
"Three per cent of travel tax doesn't sound like much, until you multiply it by ₹2,400 crore and fourteen states, and realise it has been leaking for years."
Capture first. Then take one clean view on place of supply.
The firm split the problem into two pieces, in that order. The first piece was capture: stop the bleeding by rebuilding the chain that carries invoices from carrier to ITC ledger. The firm's airline-invoice capture module ran against each of the fourteen GSTINs, pulled the carrier-issued tax invoices from the relevant portals and email queues, validated them against the booking record, and routed each one to the right return cycle. Within two cycles, the engineering of the leak was effectively closed.
The second piece was harder. The bulk of the historic leakage lived in a specific technical question: which leg of an inter-state trip generated the recoverable credit, and against which GSTIN. Cross-state travel by employees based in one state for offices in another had been booked inconsistently. Some legs were posted as IGST against the employee's home state; others as CGST/SGST against the destination office. The firm took the position that under Section 12(9) of the IGST Act, the place of supply for the transport of passengers is the location where the passenger embarks on the journey, which dictated a consistent classification across the fourteen GSTINs.
The position was led by a partner at the firm, with the assumption made explicit at the front: the recoverable credit assumes the journey is for business purposes, evidenced by the booking carrying the relevant employee identification and a cost-centre code traceable to the office of departure. The opinion named the counter-view a tax officer might run , that for round-trip travel, place of supply could plausibly attach to the origin office, and explained why the firm did not take it.
A year and a half on, the position has not been challenged.
The firm filed the recovered ITC across the relevant returns, with the documentation chain, carrier invoice, booking record, opinion, posting record, sitting in the engagement file behind every credit. Eighteen months later, no scrutiny notice has been raised on the position. The conglomerate's tax desk has been able to refer the same opinion in two subsequent advisory questions, both on travel structure of newly acquired subsidiaries.
The recovery cycle is now running quarterly. Capture is in steady state. The firm's posting module flows cleared credits into the group's SAP ledger with the audit trail stapled to each entry. The leak, for now, is closed.
What the engagement made portable for the rest of the firm's book was less the number and more the method: a place-of-supply position on inter-state employee travel, set out in writing, that can be applied against any large multi-state employer once the assumptions match. The firm has since taken three further positions sitting under the same technical line.