The appellants are not intermediaries but provide payment processing services to Airbnb, Ireland on a...

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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