Madhya Pradesh recorded 21.03 crore domestic tourist visits in 2025, up from 13.39 crore in 2024. If you own a resort here, that number is close to useless to you — and understanding why is where resort marketing in Madhya Pradesh has to begin.

Ujjain alone accounted for 8.14 crore of those visits. Kanha recorded 2.55 lakh. Bandhavgarh, 1.99 lakh. So the state's headline growth is pilgrimage volume at low yield, while the wildlife circuit — which is where most of the state's resort inventory and nearly all of its high-rate inventory sits — operates at a fraction of a percent of that traffic. Foreign arrivals were roughly flat, 1.83 lakh in 2025 against 1.82 lakh in 2023, concentrated in Khajuraho and Bandhavgarh. These are Madhya Pradesh Tourism Department figures reported in September 2026. Any agency that opens a pitch to you with "MP tourism is booming" has not looked at the split, which is why our resort and hotel engagements start with which circuit you are actually in.

Now the part that changed and almost nobody has repriced for.

Did your OTA commission get more expensive in September 2025?

For most Indian hotels, yes — without the commission rate moving at all.

The 56th GST Council rationalisation took effect on 22 September 2025. Hotel rooms with a tariff up to Rs 7,500 per night moved from 12% GST to 5% GST without input tax credit. Rooms above Rs 7,500 are at 18% with ITC. ClearTax sets out the current position, including the "specified premises" test that determines the rate on your restaurant.

The headline looked like relief. For distribution economics it was the opposite. If your rooms sit in the Rs 7,500-and-under band — and the Federation of Hotel and Restaurant Associations of India puts roughly 90% of Indian hotels in that band — you can no longer claim input tax credit on your inputs. Rent, utilities, outsourced manpower and capital expenditure all became unrecoverable, which is what FHRAI has been lobbying about.

Intermediary commission is an input too. It attracts GST, and a property in the 5% no-ITC band cannot offset that GST any more. So the effective cost of every commissioned booking rose last September for the large majority of Indian properties, quietly, while the commission percentage in the contract stayed exactly where it was.

Run that against your own numbers before you read further. It is the single most consequential change to resort distribution economics in several years and we have not seen one agency deck mention it.

What is the Comparable Line?

Draw a line through your book of business.

Above the line is everything a guest can price-compare: the room, the night, the bed type. It is a commodity. It appears next to eleven alternatives on a screen, sorted by price. On that ground an intermediary beats you permanently, because it owns discovery and you do not.

Below the line is everything a guest cannot price-compare: the safari arrangement, the airport or railhead transfer, the naturalist, the meal plan, the two-night itinerary with a specific gate on a specific morning, the room with the particular view, the early-breakfast-before-the-gate-opens logistics that only you can actually deliver.

The Comparable Line is the discipline of measuring how much of your revenue sits above it, and deliberately moving revenue below it. Not because commission is evil, but because above the line you are selling a substitutable product and below it you are selling something with no comparison set — which means no price pressure, higher attach rates and a guest who booked a stay rather than a room.

Most independent resorts in this state have 70% or more of their revenue above the line and almost no infrastructure for selling below it. That is the gap, and it is a bigger number than the commission rate.

Can you legally undercut your OTA price on your own website?

This is where you need to be careful, because the confident answer circulating online overstates what was actually decided.

In October 2022 the Competition Commission of India penalised MakeMyTrip-Goibibo approximately Rs 223 crore and OYO approximately Rs 169 crore — about Rs 392 crore combined, each 5% of relevant turnover — following a complaint by FHRAI. The CCI directed MakeMyTrip-Goibibo to modify its hotel agreements to remove the price and room availability parity obligations, and the exclusivity conditions. As Medianama reported the directions at the time, the parity obligations were to be removed with respect to other online travel aggregators.

Read that again, because the distinction matters commercially. A direction to stop requiring parity against other OTAs is not the same thing as a direction to stop requiring parity against your own website. Competition law elsewhere calls the first wide parity and the second narrow parity, and they are treated differently. Plenty of material online collapses the two and tells hoteliers that Indian law now guarantees them the right to undercut. The order as reported does not clearly say that, the penalties went through appeal, and your position depends on the contract you actually signed.

So the honest advice: do not take a blog's word for this, and do not take ours. Have someone read your intermediary agreement and tell you what parity clause it contains and whether it reaches your direct channel. That is a two-hour job for a competent advisor and it determines whether half the strategy below is available to you.

There is also a commercial reality independent of the legal one. Visibility suppression, punitive rate matching and delisting pressure do not require a lawful clause to hurt a property that depends on one channel for most of its occupancy. A right you cannot afford to exercise is not much of a right. Which is the strongest argument for the Comparable Line: a bundle priced as a package has no directly comparable rate to breach parity against in the first place.

Can you stop an OTA bidding on your resort's name?

No, and this one is settled.

In December 2023 a Division Bench of the Delhi High Court set aside an injunction and held that using a competitor's trademark as a search keyword is not, by itself, infringement where there is no confusion or unfair advantage. The court relied on the earlier reasoning in Google LLC v. DRS Logistics, and reasoned that a user searching a brand name is not necessarily looking for that brand's website — they may want reviews, or alternatives. SpicyIP's analysis of the ruling sets out the reasoning properly. MakeMyTrip's further appeal to the Supreme Court was dismissed.

The practical consequence for your resort: a legal notice will not clear intermediaries off your branded search term. You defend it commercially or not at all — which means owning the organic result, owning your Google Business Profile, and deciding whether to bid on your own name.

That last decision is a real one, not a reflex. If a guest searching your resort by name finds your own site first and the booking path is obvious, a paid click on your own brand may be money spent on traffic you already had. If intermediaries sit above you with a cheaper headline rate, it is defensive spend with a measurable payback. The way to settle it is a holdout test, not an opinion — which is the general principle in measuring marketing properly.

Worth knowing that Google offers free booking links alongside paid hotel ads: a property with an active Business Profile and rates and availability synchronised through a certified channel manager or property management system can appear organically in the booking module. Google's Hotel Center documentation sets out what participation requires, including that your displayed price must match what the guest actually pays at checkout.

What can your own booking engine legally not do?

The conversion tactics you would copy from an intermediary's site are, in several cases, the enumerated ones.

The Central Consumer Protection Authority's Guidelines for the Prevention and Regulation of Dark Patterns, 2023, were notified in November 2023 under the Consumer Protection Act, 2019. Two of the listed practices land directly on hotel booking funnels:

Drip pricing — revealing parts of the price late in the checkout flow. Showing a bare room rate and only surfacing GST or a mandatory resort fee at the payment step is the practice described. Note how badly this interacts with Google's own price-accuracy requirement: both push you toward displaying the real, total, all-in number upfront.

False urgency — stating or implying scarcity to mislead. "Only 1 room left" is fine when one room is left. It is a deceptive practice when your inventory does not support it, and so is an inflated "14 people are viewing this property."

The guidelines are worth reading in full. The uncomfortable implication is that some of what your intermediary does on its own platform is not available to you, and your booking engine vendor's default template may have shipped with it switched on.

Is your guest database actually yours to market to?

Not automatically, and the compliance clock is now running.

The Digital Personal Data Protection Act, 2023 requires consent that is free, specific, informed, unconditional and unambiguous, given by clear affirmative action. The practical effect for a resort is that an email address collected to deliver the stay does not come with permission to send an October offer. Marketing consent has to be separate, specific and unbundled — and you cannot refuse a guest a room because they declined it. Withdrawal has to be as easy as consent was, which rules out making people email you to unsubscribe when the opt-in was a single click.

The Rules under the Act were notified on 14 November 2025, with phased compliance over an eighteen-month window. The Government's own explainer sets out the notice and consent requirements. For a 30-room property this is not optional housekeeping; it is a consent capture process at check-in and a clean record of who said yes to what.

Two related points. Reporting foreign guests is a separate legal obligation that consent does not touch — and it moved: the Immigration and Foreigners Act, 2025 replaced the older framework from September 2025, Form C filing within 24 hours of arrival remains, and reported penalties run to Rs 50,000 per unreported guest. Anyone citing the Foreigners Act, 1946 at you is working from a repealed statute. And reactivating a database by SMS or voice means operating inside India's commercial communication regime — DLT registration, registered sender headers, pre-approved templates — with telecom resources barred for violations. A casual promotional blast is not a casual thing.

What should a Madhya Pradesh resort actually do?

The sequence matters more than the tactics.

1. Split the book by circuit and by the Comparable Line. Wildlife, pilgrimage, heritage and hill station are four businesses with different seasons, lead times and guest profiles. Work out what share of your revenue is price-comparable room-nights and what share is not. That single number sets the strategy.

2. Reprice distribution post-GST. Recalculate effective commission cost with ITC unavailable if you sit in the 5% band. Compare it honestly against what a direct channel costs you all-in — booking engine, gateway charges, channel manager, site, and the staff hours nobody counts.

3. Get the parity clause read. Before you build a direct pricing advantage, find out whether you are contractually permitted to offer one and what the commercial exposure is if you do.

4. Build below-the-line inventory, carefully. Transfers, meal plans, naturalist time, multi-day itineraries, specific rooms. On safari permits, be precise: permits are rationed and controlled by the forest department through a central booking system, and a lodge facilitates rather than owns that inventory. Sell the arrangement and the logistics you genuinely control; do not promise a permit you cannot guarantee, because one failed morning at the gate costs you a review that costs you far more than the booking.

5. Own the branded result. Organic result, Business Profile, free booking links, accurate all-in pricing. Then test paid brand defence with a holdout rather than assuming it.

6. Fix consent at check-in. Separate marketing opt-in, recorded, with easy withdrawal. Then the database is an asset rather than a liability.

7. Win the pre-booking question. Guests researching a safari lodge ask specific things — which gate, which months, what a morning actually looks like, whether children are allowed, how far the railhead is. Answering those precisely is how an independent property gets found and gets cited, and it is the same work whether the reader arrives from a search result or from an AI assistant's answer. Search visibility is one discipline, not three, which is the argument we make in what SEO actually is now and in our approach to AI-powered marketing. It also happens to be the content that carries into social channels without being rewritten.

When you should not do any of this

Three situations where we would tell you to keep paying commission, and we would rather say so now than four months into a retainer.

Your season is too short to amortise fixed cost. Commission is purely variable. A booking engine subscription, a channel manager, a payment gateway and a marketing retainer are not. If you have four or five viable months, the all-in cost of a direct channel spread over that window can exceed the commission you avoid. This is real arithmetic, not a counsel of despair, and it is the reason most lead generation programmes fail at properties this size.

You have no demand outside your circuit. Intermediaries function as discovery engines. Cornell's research on what is called the billboard effect found that listing on a major platform increased a hotel's own direct bookings materially — the original study is worth reading, with the caveat that it is Expedia data from around 2009 in the United States market, and nobody has replicated it for Indian leisure properties. Treat it as a real mechanism of unknown magnitude here rather than a number to plug into a model. If an unknown guest cannot find you except through a platform, commission is a customer acquisition cost and a reasonable one.

Your constraint is not demand. If the limit on your occupancy is permit availability, road access, connectivity or room count, marketing cannot move it. More enquiries into a property that cannot serve them produces worse reviews, not more revenue. We will tell you this in the first conversation.

Want the arithmetic done on your property? Send us your channel mix, your current commission slabs, your room tariff band and your occupancy by month, and we will come back with the post-GST effective cost of each channel, what share of your revenue is price-comparable, and whether a direct strategy clears its own cost at your scale. If it does not, we will say so. Talk to Midgrow, or message +91 9632398896 with your property name and circuit. If you want to understand what this work costs before you speak to anyone, we published what agencies do not tell you about pricing, and our wider digital marketing services page sets out how engagements are structured.

Frequently asked questions

What commission do OTAs charge hotels in India?

Commission is contractually negotiated per property and varies by market, by room type and by participation in preferred-visibility programmes, so any single confident percentage you read is unreliable. Published investor disclosures by listed travel platforms give blended take rates for accommodation in the high teens, while wholesale B2B distribution runs considerably lower. The number that matters is the one in your own contract, plus the GST you can no longer offset if you are in the 5% band.

Can an Indian hotel offer a lower price on its own website than on an OTA?

The CCI's October 2022 order directed MakeMyTrip-Goibibo to remove price and room availability parity obligations with respect to other online travel aggregators, along with exclusivity conditions. Whether that extends to parity against a hotel's own direct channel is not clearly settled by that direction, and your position depends on your agreement. Get the contract reviewed before building a pricing strategy on it.

What is the GST rate on hotel rooms in India now?

Since 22 September 2025, rooms with a tariff up to Rs 7,500 per night attract 5% GST with no input tax credit, and rooms above Rs 7,500 attract 18% with input tax credit. The earlier rate for the lower band was 12%. The loss of ITC in the 5% band makes every input, including intermediary commission, more expensive in real terms.

Can I stop an OTA from bidding on my hotel's name in Google Ads?

Not through a legal notice. The Delhi High Court held in December 2023 that keyword use of a competitor's trademark is not infringement absent confusion or unfair advantage, and MakeMyTrip's appeal to the Supreme Court was dismissed. Branded search has to be defended commercially — strong organic presence, a well-kept Business Profile, free booking links, and a tested decision on whether to bid on your own name.

Is "only 2 rooms left" allowed on a hotel booking engine?

Only when it is true. The CCPA's 2023 dark patterns guidelines enumerate false urgency as a prohibited practice, so a scarcity message the backend inventory does not support is deceptive. The same guidelines cover drip pricing, which means taxes and mandatory fees should be visible upfront rather than appearing at the payment step.

Can a resort email past guests with offers?

Only with consent that was specific to marketing. Under the Digital Personal Data Protection Act, 2023, consent must be free, specific, informed, unconditional and unambiguous, so an address taken to deliver the stay does not carry permission to market. The Rules were notified on 14 November 2025 with phased compliance over eighteen months. Capture a separate opt-in at check-in and keep the record.

Can a lodge sell safari permits as part of a package?

Permits are rationed and controlled by the forest department through a central booking system, so a lodge facilitates rather than owns that inventory. Sell the arrangement, the transfers, the timing and the naturalist — the parts you control — and be explicit in your terms about permit availability. Guaranteeing a permit you cannot secure is the fastest route to a damaging review.

Should a small resort in Madhya Pradesh invest in direct booking at all?

It depends on season length and base demand. Commission is a variable cost; direct infrastructure is largely fixed. A property with four or five viable months and no recognition outside its circuit may genuinely be better off paying commission. Do the arithmetic on your own occupancy curve before committing to a retainer, and treat any agency unwilling to run that calculation with you as a warning.