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

**Category:** GST | **Published:** 2026-05-05 | **Last reviewed:** 2026-06-19 | **Author:** Mrs. Swapna Patel

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.

> **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](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-act).

## 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](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-act), 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](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-rules-as-amended). 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](https://hrareceipt.in/atlas/tax-invoice-vs-bill-of-supply-vs-kaccha-decision-tree)**

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

> **Short answer:** Under [Rule 49 of the CGST Rules](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-rules-as-amended) 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.

| Element | Tax invoice | Bill of supply |
| --- | --- | --- |
| Title | TAX INVOICE | BILL OF SUPPLY |
| Supplier GSTIN | Shown | Omitted (or composition GSTIN) |
| CGST/SGST/IGST lines | Shown | None |
| Tax-rate column | Per item | None |
| Total value | With tax | Excludes GST |
| Buyer ITC | Available | Not 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](https://hrareceipt.in/pakka-bill)**

## 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](https://www.cbic.gov.in/htdocs-cbec/gst/notifications), 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](/pakka-bill); 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](/misc-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.

## Primary sources

- [Rule 49, Central Goods and Services Tax Rules 2017 — CBIC](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-rules-as-amended) — Bill of supply mandatory fields
- [Section 31(3)(c), CGST Act 2017 — CBIC](https://www.cbic.gov.in/htdocs-cbec/gst/cgst-act) — Statutory basis for bill of supply
- [GST registration threshold notification — CBIC](https://www.cbic.gov.in/htdocs-cbec/gst/notifications) — Rs. 20 lakh / Rs. 10 lakh special-category-state threshold

## Related

- [Composition vs Unregistered: Which Bill of Supply?](https://hrareceipt.in/answers/composition-vs-unregistered-bill-of-supply-when)
- [GST Invoice (Pakka Bill) Generator](https://hrareceipt.in/pakka-bill)

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*Source: [No GSTIN but Client Wants an Invoice? Issue a Bill of Supply](https://hrareceipt.in/answers/non-gst-invoice-format-bill-of-supply) — HRAReceipt.in*
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