Hotel accommodation arrangement services fall under support services, not tour operator service, with input tax credit available under GST.

Arranging hotel accommodation for clients, without more, is not tour operator service because tour operating covers planning and organising tours with transport, while accommodation is only ancillary where relevant. A standalone accommodation-arrangement service does not fall under hotel accommodation service supplied by hotels themselves; it is classifiable as support services under SAC 998552, taxable under the relevant rate entry. On that classification, the applicant is eligible to claim input tax credit on GST charged by hotels, subject to the GST law's admissibility conditions.

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Issues: (i) Whether arranging hotel accommodation for clients, without more, is classifiable as tour operator service or falls under support services classified under SAC 998552; (ii) Whether the applicant is entitled to input tax credit on the GST charged by hotels in relation to such accommodation arrangements.

Issue (i): Whether arranging hotel accommodation for clients, without more, is classifiable as tour operator service or falls under support services classified under SAC 998552.

Analysis: Tour operator service under the rate notification is concerned with planning, scheduling, organising and arranging tours by any mode of transport, with accommodation being only an ancillary feature where relevant. A standalone service of arranging accommodation in hotels is not the essence of tour operating. Accommodation service under SAC 996311 is limited to the service provided by hotels and similar establishments, and therefore does not cover an intermediary who merely arranges such accommodation. The service is instead covered by the entry for support services, which includes arranging reservations for accommodation services.

Conclusion: The service is not tour operator service and is classifiable under SAC 998552, taxable under Sl. No. 23(iii) of the rate notification.

Issue (ii): Whether the applicant is entitled to input tax credit on the GST charged by hotels in relation to such accommodation arrangements.

Analysis: Once the supply is classified under SAC 998552 and taxed under the applicable entry, the applicant is entitled to avail input tax credit to the extent admissible under the GST law.

Conclusion: The applicant is eligible to claim input tax credit as admissible under the law.

Final Conclusion: The ruling accepts the applicant's classification as a provider of support services for hotel accommodation arrangements and confirms eligibility to claim input tax credit subject to the GST framework.

Ratio Decidendi: A service consisting merely of arranging hotel accommodation is not tour operating service; it falls within the specific support-service entry for arranging accommodation reservations, with consequential eligibility to input tax credit under the GST law.

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