How to Make an Invoice Without GST for Non-Registered Businesses

If your business is not GST-registered, you are legally allowed to issue an invoice without GST in India but only if it follows a specific format and avoids charging tax. This guide shows exactly how to create a compliant non-GST invoice, what most business owners get wrong, and how to stay safe during audits.

What Most Business Owners Get Wrong

Many small business owners believe one of these myths:

• “Without GST, I can’t issue a proper invoice”

• “Invoices without GST are illegal”

• “I can just remove GST fields and I’m done”

• “Customers won’t accept a non-GST invoice”

All of these are partially or fully wrong.

In India, GST registration is mandatory only after crossing a turnover threshold (₹40 lakh for goods, ₹20 lakh for services in most states). Until then, issuing an invoice without GST in India is completely valid if done correctly.

The problem is not whether you can issue a non-GST invoice.

The problem is how most people do it incorrectly.

How to Make a Valid Invoice Without GST (Step-by-Step)

A proper invoice without GST in India is not a “half invoice” or a “temporary bill.”

It is a complete commercial document just without tax components.

Let’s break this into clear, actionable steps.

Step 1: Confirm You Are Eligible to Issue a Non-GST Invoice

You should issue an invoice without GST only if:

• You are not registered under GST

• Your turnover is below the GST threshold

• You have not opted for voluntary GST registration

📌 Important contradiction people miss:

Even if your customer is GST-registered, you still must not charge GST if you are not registered.

CBIC clarification: Only GST-registered suppliers can collect GST. Charging GST without registration is illegal.

Step 2: Use the Correct Invoice Title (This Matters)

Do not label your document as “Tax Invoice.”

Instead, use one of these:

• Invoice

• Bill of Supply

• Commercial Invoice

Best practice:

“Invoice (Non-GST)”

This small wording choice avoids future disputes and audit confusion when issuing an invoice without GST in India.

Step 3: Mandatory Details Every Non-GST Invoice Must Have

Even without GST, your invoice must still look professional and complete.

Required Elements:

1. Seller Details

• Business name

• Address

• Phone number

• Email

• (Optional) PAN

2. Invoice Information

• Invoice number (unique & sequential)

• Invoice date

3. Buyer Details

• Name

• Address

• Phone/email (recommended)

4. Product or Service Details

• Description

• Quantity

• Rate

• Total amount

5. Total Payable Amount

• Clearly mention “No GST charged”

6. Declaration Statement

• “Supplier is not registered under GST. GST not applicable.”

This declaration is critical when issuing an invoice without GST in India.

Step 4: What You Must NOT Include (Common Legal Mistakes)

Never include the following in a non-GST invoice:

• ❌ GSTIN

• ❌ CGST / SGST / IGST columns

• ❌ HSN/SAC (optional but unnecessary)

• ❌ “Tax Invoice” heading

• ❌ Any GST percentage or amount

Charging GST without registration can attract:

• Penalty under Section 122 of CGST Act

• Refund liability to customers

• Compliance notices

GST vs Non-GST Invoice (Quick Comparison)

Step 5: Numbering & Record-Keeping (Often Ignored, Always Risky)

Even without GST, invoices must be:

• Sequentially numbered

• Not duplicated

• Stored for at least 6 years (recommended)

Why this matters:

• Banks ask for invoices during loan applications

• Customers may request past invoices

• Income tax scrutiny relies on invoice trails

A clean numbering system makes your invoice without GST in India defensible.

Real-World Examples (Clear, Practical)

Example 1: Freelance Graphic Designer

• Annual turnover: ₹8 lakh

• GST registration: No

• Client: Startup in Bengaluru

✅ Correct approach:

• Issue an invoice without GST in India

• Mention “GST not applicable”

• Client cannot claim ITC and that’s legally fine

Example 2: Local Retail Shop

• Sells stationery

• Turnover: ₹25 lakh

• Walk-in customers

✅ Correct approach:

• Issue non-GST invoices

• No tax breakup

• Maintain daily sales summary

Example 3: Service Provider Near Threshold

• Turnover: ₹18 lakh

• Approaching ₹20 lakh limit

⚠️ Best practice:

Monitor turnover monthly

Prepare to shift from invoice without GST in India to GST invoice immediately after crossing threshold

Delay here is one of the most penalized GST mistakes.

What About E-Invoices, WhatsApp Bills & PDFs?

Yes an invoice without GST in India can be:

• Printed

• Shared as PDF

• Sent on WhatsApp

• Generated digitally

As long as:

• Mandatory fields are present

• No GST is charged

• Declaration is included

Format > Medium

Data & Authority: Why This Is Legally Sound

• GST Act, Section 22: Registration only after threshold

• CBIC FAQs: Unregistered persons cannot collect GST

• MSME Ministry Data (2023): Over 85% of Indian businesses are unregistered under GST

This means issuing an invoice without GST in India is not an exception it is the norm for small businesses.

What Happens If You Accidentally Charge GST?

If you charge GST without registration:

• You must deposit the tax to the government

• You cannot keep it

• You may face penalties

This is why clarity in your invoice without GST in India is not optional—it’s protective.

Something Every Business Owner Should Remember

An invoice is not just a payment slip.

It is a legal representation of your business status.

A clean, compliant invoice without GST in India:

• Builds customer trust

• Protects you during scrutiny

• Keeps you audit-ready

• Simplifies future GST transition

FAQ