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Paypal INR dispute opened after 28 hours - 7 day delivery estimate

Buyer takes 3 days to pay on an ebay auction. 28 hours after payment, paypal has let them open an INR case and put my paypal account into a negative balance.
My ebay delivery is 2 days dispatch sent via 3-5 day courier.

Is this the new norm now that ebay and paypal have spilt? I.e buyers can simply bypass ebay and open paypal disputes as soon as they like?
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