No GSTIN but Client Wants an Invoice? Issue a Bill of Supply

A bill of supply is a GST sale document that carries no tax: a registered or below-threshold seller issues it in place of a tax invoice whenever GST is not chargeable on the supply. You cannot issue a tax invoice with a GSTIN you do not have, so the bill of supply is the substitute, with its format set by Rule 49 of the CGST Rules^[1]. It records the seller, the buyer, and the value, but has no CGST, SGST, or IGST line. Most clients accept it once you explain you are below the threshold and not charging GST.

The choice is set by your registration status, not by the look of the document. A registered regular supplier making a taxable supply issues a tax invoice; a composition or exempt-goods supplier, or an unregistered seller below the threshold, issues a bill of supply. A kaccha bill, the informal slip with no GSTIN and no tax split, is none of these and is not a GST document at all.

• →You are below the GST threshold (Rs. 20 lakh aggregate annual turnover, or Rs. 10 lakh in special-category states) and have not voluntarily registered.
• →You are registered but supplying exempt goods or services, such as educational services or healthcare.
• →You are a composition-scheme dealer (turnover up to Rs. 1.5 crore, taxed at a fixed rate without ITC); composition dealers issue bills of supply, not tax invoices.
• →A registered regular taxpayer making a taxable supply must issue a tax invoice, never a bill of supply; the two are not interchangeable.

• →Supplier name and address; GSTIN is omitted for unregistered suppliers, but composition or exempt suppliers include theirs.
• →A unique serial number, in one or multiple series, not exceeding 16 characters of alphabets, numbers, and special characters.
• →Date of issue, plus recipient name, address, and (if available) GSTIN.
• →HSN/SAC code and description of the goods or services.
• →Value of supply with no tax breakdown; bills of supply do not show CGST/SGST/IGST.
• →Signature or digital signature of the supplier or authorised representative.

A B2B buyer asking specifically for ITC must source from a registered supplier; a bill of supply will not satisfy that need.

For a freelancer billing Rs. 5-8 lakh annually with mostly individual clients, staying unregistered and issuing bills of supply usually wins on net.

• →Register if B2B clients require ITC, since corporate buyers often will not engage suppliers who cannot issue tax invoices.
• →Register if input costs carry significant GST: Rs. 5 lakh of inputs at 18% is Rs. 75,000 of input tax to offset against output tax.
• →Register if you are approaching the Rs. 20 lakh threshold organically and want to avoid a mid-year transition.
• →Against it: registration adds monthly GSTR-1, GSTR-3B and annual GSTR-9 filings, accountant fees, and late fees if missed.

• →You have no GSTIN, so no GST is charged and no GST line items appear.
• →The bill of supply is still valid proof of expense for their income tax and accounting records.
• →They cannot claim ITC on this transaction because no GST is collected.
• →If a corporate AP process accepts only tax invoices, voluntary registration or a higher rate to offset their lost ITC may be the only path.

Save your business profile so each repeat document takes about 30 seconds. Pair it with a payment receipt once funds clear, carrying the UTR number for digital transfers and a revenue stamp placeholder for cash above Rs. 5,000. This two-document workflow is the cleanest paper trail for unregistered service providers handling B2B clients.