The additional director general, Directorate General of GST Intelligence, had argued that MMT India wasn't a tour operator as it was providing short-term hotel accommodation service and imposed a tax liability of ₹798 crore on the company. However, the bench of Justice Dilip Gupta and member (technical) Hemambika R. Priya held that "any person who is engaged in the business of planning, scheduling, organising, arranging tours, including accommodation, would be a tour operator".