Civil Appeal No. 8228/2019 etc. NON-REPORTABLE 2024 INSC 808 IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 8228 OF 2019 COMMISSIONER OF GST AND CENTRAL EXCISE ..... APPELLANT VERSUS M/S CITIBANK N.A. ..... RESPONDENT WITH CIVIL APPEAL NO. 89 OF 2021 J U D G M E N T SANJIV KHANNA, J. We have heard the learned counsel appearing for the parties at some length. 2. The contention of the Revenue is that the acquiring bank should have paid service tax on the Merchant Discount Rate1 minus the interchange fee, and the issuing bank should have paid service tax on the interchange fee. 3. We are of the view that the judgment and reasoning given by S. Ravindra Bhat, J. is acceptable and it is in accordance with the provisions of Clause (iii) of Section 65 (33a) of 1 For short, “MDR”. 1Civil Appeal No. 8228/2019 etc. the Finance Act, 19942. 4. S. Ravindra Bhat, J. rightly observes that as per Section 65(33a) of the Act, seven distinct heads of credit card services were