For most of GST's first five years, hotel e-invoicing was a question that applied to a narrow slice of the hospitality industry. The threshold for mandatory e-invoicing was set high; many independent hotels, smaller chains, and the long tail of city properties that an enterprise actually uses for routine business travel sat comfortably below it. Practitioners advising on hotel input tax credit built their work around that assumption. They built GSTIN maps. They chased invoices. They reconciled what they could and wrote off the rest.
That world is over. After three downward revisions to the turnover threshold, the share of enterprise hotel spend now subject to mandatory e-invoicing has crossed the line from "some" to "almost everything". The practitioner's job has not stayed the same.
A rule that has been quietly rewriting itself for three years.
Rule 48 of the CGST Rules, 2017 prescribes the form and manner of issue of tax invoices, and via sub-rule (4) requires registered persons whose aggregate turnover in any preceding financial year from FY 2017–18 onwards exceeds the prescribed threshold to issue invoices in the e-invoicing form, effectively, registered with the Invoice Registration Portal and carrying an Invoice Reference Number.
The prescribed threshold started at ₹500 crore in October 2020. It has since stepped down through ₹100 crore, ₹50 crore, ₹20 crore, ₹10 crore, and most recently to ₹5 crore . Each reduction has been notified separately. Each one has pulled a wider ring of supplying entities into the mandatory regime.
For travel tax practitioners, the most consequential of those reductions is the most recent. The hotels an enterprise actually books , midscale and upscale brands, large independent properties, the big-city business properties, almost universally clear the current threshold. Where five years ago a practitioner could assume that only the marquee national-chain properties issued e-invoices, today the default assumption has flipped.
"The default has flipped. Five years ago, only the marquee national chain properties issued e-invoices. Today, almost any hotel an enterprise actually uses does, and the practitioner's work has to follow."
From building the map to trusting the portal.
The old practitioner posture on hotel ITC was essentially a posture of capture. Find the hotel. Confirm its GSTIN. Get the tax invoice issued correctly, with the corporate as recipient and the right state of supply, and chase it until it arrived. Roll the result up into a recovery cycle. The work was logistical, and most of the judgement sat in the assembly: did this invoice come from a registered person, in the right form, with the right particulars, against a real business booking?
E-invoicing changes the shape of the work because it changes where the source of truth sits. Where the supplier is in the mandatory regime, the authoritative tax invoice is the one carrying the IRN, and that record is reflected back to the recipient in the GSTR-2B view from the portal. The practitioner's job is no longer to assemble the credit from primary documents collected hotel by hotel; it is to verify that the portal feed reflects what the booking record says it should.
That is a small change in description and a large change in practice. A capture-led tax desk and a verification-led tax desk run on different people, different tools, and different cadences. The reconciliation runs differently. The exception queue looks different. The defence dossier, if it is ever needed, is structured differently. Practitioners who built around the old assumption have work to redo.
Trust, but verify. Don't trust without verifying.
The firm's reading is that the right operational posture has three parts. First: assume by default that any enterprise hotel booking sits inside the e-invoicing regime, and structure capture around the portal feed rather than around supplier-by-supplier chase. Second: keep a clearly-defined exception queue for bookings that fall outside the regime, small independent properties below the threshold, certain alternative-stay categories, and properties whose registration status is unconfirmed. These need the old capture-led approach.
Third, and this is the part most often missed: do not assume the portal is right. The IRN-bearing invoice is the authoritative tax record, but the portal's reflection back to the recipient is a feed, and feeds break. They break on the recipient GSTIN being mis-keyed. They break on date-of-supply errors. They break on place-of-supply mis-classification. A verification-led practice has to be willing to flag a portal record against the booking record and chase the supplier for correction, exactly the way a capture-led practice chased the absence of an invoice.
Three practical things worth doing this quarter.
None of this changes the underlying point that hotel ITC is recoverable and worth recovering. Travel programmes at enterprise scale still carry ITC opportunities that compound over years if a tax desk is willing to do the work. What has changed is the shape of the work itself — and the firm's view is that the practitioners who notice the change quickest will recover more credit, and defend it more cleanly, than the ones who don't.