It would be entirely legit to conduct an intro training flight (aka discovery flight) while also pointing out local sights.
However...if the FSDO asked your customers what they were doing, they'd better be at least entertaining the possibility of learning to fly. And hopefully some of your disco flight customers have actually signed up as regular students. Any advertising you're doing had better be all about flight training.
If you think you're going to game the regulations and run a an air tour op under the guise of flight instruction, think again. As dumb as the FAA might be, they're smarter than a brand new CFI and they've seen it all before. Also any legit certificate holders in your area will dime you out the moment they get a inkling of what you're doing.