https://www.taxtmi.com/forum/issue?id=119720 The central dispute is whether a government payment certificate can establish that payments pertain to the pre GST service tax period and support exemption under Notification No. 25/2012 ST; the department has confined exemption to vouchers dated before the transition cut off, issued a demand for later vouchers, and sought the underlying agreement which the client lacks. Advisers emphasize that the burden of proof to substantiate exemptions lies with the service provider, that payment certificates are secondary evidentiary material to be considered later, and that reliance on an implied contract may be explored when a written agreement is unavailable. en-us Fri, 14 Mar 2025 10:35:05 +0530 Sat, 15 Mar 2025 08:18:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=119720 The central dispute is whether a government payment certificate can establish that payments pertain to the pre GST service tax period and support exemption under Notification No. 25/2012 ST; the department has confined exemption to vouchers dated before the transition cut off, issued a demand for later vouchers, and sought the underlying agreement which the client lacks. Advisers emphasize that the burden of proof to substantiate exemptions lies with the service provider, that payment certificates are secondary evidentiary material to be considered later, and that reliance on an implied contract may be explored when a written agreement is unavailable. Discussion-Forum Service Tax Fri, 14 Mar 2025 10:35:05 +0530 https://www.taxtmi.com/forum/issue?id=119720