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GST · 5 May 2026

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

If you're below the Rs. 20 lakh services / Rs. 40 lakh goods GST registration threshold and have no GSTIN, the correct buyer-facing document is a Bill of Supply under Rule 49 of the CGST Rules. Format matches a tax invoice, with the GSTIN line replaced by your PAN and a 'no GST charged' declaration. Input Tax Credit is unavailable to the buyer.

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Myth

An unregistered seller can just issue a tax invoice without charging GST.

Fact

A tax invoice requires a GSTIN. Without registration you must issue a bill of supply under Section 31(3)(c) of the CGST Act 2017[2].

A client wants a GST invoice but I'm not GST-registered. What do I issue?

Short answer

Issue a bill of supply under Section 31(3)(c) of the CGST Act 2017[2], the lawful document for an unregistered seller.

You cannot issue a tax invoice with a GSTIN you do not have. The bill of supply is the substitute, with its format set by Rule 49 of the CGST Rules[1]. Most clients accept it once you explain you are below the threshold and not charging GST.

When do you issue a bill of supply instead of a tax invoice?

Short answer

Three cases trigger it: below-threshold unregistered, exempt supplies, or a composition-scheme dealer.

  • 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.
See the decision tree

What fields are mandatory on a bill of supply under Rule 49?

Short answer

Under Rule 49 of the CGST Rules[1] the document must be titled 'BILL OF SUPPLY' and carry these fields.

  • 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.

How does a bill of supply differ from a tax invoice?

Short answer

Both share most fields, but only a tax invoice shows GST line items and generates ITC.

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

ElementTax invoiceBill of supply
TitleTAX INVOICEBILL OF SUPPLY
Supplier GSTINShownOmitted (or composition GSTIN)
CGST/SGST/IGST linesShownNone
Tax-rate columnPer itemNone
Total valueWith taxExcludes GST
Buyer ITCAvailableNot available

Bill of supply vs tax invoice. Source: Rule 46 and Rule 49, CGST Rules 2017, CBIC.

Generate a bill of supply or tax invoice

Should you voluntarily register for GST below the threshold?

Short answer

Register if B2B clients need ITC or your input GST is large enough to recover; otherwise the compliance cost usually loses.

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.

How do you explain a bill of supply to a client who demands a tax invoice?

Short answer

State that you are below the Rs. 20 lakh registration threshold[3], so Section 31(3)(c) requires a bill of supply, not a tax invoice.

  • 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.

How do you generate a compliant bill of supply quickly?

Short answer

Use the pakka bill generator; leave the GSTIN field blank and the title renders as 'BILL OF SUPPLY'. Free watermarked preview, Rs. 9 for the clean PDF.

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.

References

  1. 1.Rule 49, Central Goods and Services Tax Rules 2017 — CBIC — Bill of supply mandatory fields
  2. 2.Section 31(3)(c), CGST Act 2017 — CBIC — Statutory basis for bill of supply
  3. 3.GST registration threshold notification — CBIC — Rs. 20 lakh / Rs. 10 lakh special-category-state threshold

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