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        Case ID :
        Service Tax

        The appellants are not intermediaries but provide payment...

        Payment Processors for Airbnb Deemed Exporters, Entitled to Tax Refunds; No Principal-Agent Role Found.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The appellants are not intermediaries but provide payment processing services to Airbnb, Ireland on a principal-to-principal basis. The conditions for being an intermediary under the Genpact case are not satisfied as there is no principal-agent relationship, and the appellants do not facilitate the main service provided by Airbnb. The appellants merely process payments to ensure property owners receive consideration for renting to Airbnb, without any involvement with Airbnb's customers. The appellants provide a single service of payment processing to Airbnb and have no tripartite agreement or commission-based arrangement. Their services qualify as export of services u/r 6A of the Service Tax Rules, making them eligible for refunds claimed and not liable for service tax. Consequently, the impugned orders are set aside, and the appeal is allowed.
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