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GST Invoice-cum-Bill of Supply: Rule 46A for Taxable and Exempt Supplies to an Unregistered Customer

GST Invoice-cum-Bill of Supply: Rule 46A for Taxable and Exempt Supplies to an Unregistered Customer

Rule 46A permits a single invoice-cum-bill of supply for taxable and exempt supplies to an unregistered recipient. Preserve the required particulars and separate the taxable and exempt values; combining the document does not determine composite or mixed-supply classification.

Reviewed by CA Manoj Mittal · Chartered Accountant | 30+ years in GST & Indirect Taxation

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One document is permitted for the stated combination

CGST rule 46A permits a registered person supplying taxable and exempted goods or services or both to an unregistered person to issue a single invoice-cum-bill of supply. Its proviso requires particulars under rule 46 or rule 54, as applicable, and rule 49. It is a documentation option for that scope, not a blanket relaxation for every buyer and every tax status.

Verify the recipient and each supply

Confirm that the actual recipient is unregistered and the supplier's actual supplies include taxable and exempt elements. Preserve rate and exemption evidence for the relevant date. A customer without a GSTIN printed on one screen is not automatically proven unregistered. Do not extend the option to a registered recipient solely because staff prefer a combined template.

Document combination is not supply classification

The rule does not by itself decide whether the transaction is a composite supply, a mixed supply or genuinely separate supplies. Determine classification and its tax consequence first, including applicable section 8 analysis where relevant. Do not place an exempt label on one contractual element merely to reduce the taxable base. All illustrations stipulate independent supplies correctly classified as taxable or exempt.

Keep particulars and tax columns intelligible

The proviso preserves the required tax-invoice/special-document and bill-of-supply particulars. Build a template that records the actual descriptions, values and applicable tax details without taxing an exempt line by accident. A single grand total does not replace those particulars or establish which portion is taxable. Special supplier/document provisions need their own review.

Reconcile to sales and tax records separately

Post taxable turnover, exempt turnover and output tax to the proper ledger/reporting compartments. The combined document does not make exempt value taxable, remove the taxable lines' tax or permit a second duplicate sale through a separate bill import. Preserve one document identity and trace the line-level accounting to it.

Handle inclusive prices and corrections on evidence

If the taxable component is genuinely tax-inclusive, extract its tax using the correctly established rate and value. Do not divide the entire receipt by that factor where it also includes separately exempt consideration. Discounts, cancellations and later changes require their own valuation and document analysis. Assumed rates of 18% and 5% below are for arithmetic and do not identify actual product rates, exemptions, ITC entitlement or e-invoice applicability.

Framework checked on 26 October 2026. Read the primary provisions.

Six worked illustrations

All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.

Illustrative example 1: One taxable and one exempt supply

Assume taxable value ₹1,000 at the correctly established model 18% rate and separate exempt supply ₹500. Tax is ₹180 and combined payable ₹1,680; only ₹1,000 is taxable value.

Illustrative example 2: Do not tax the exempt line

On those facts, applying 18% to the full ₹1,500 would produce ₹270 tax instead of ₹180, an excess ₹90. A combined document does not support that shortcut.

Illustrative example 3: Inclusive taxable component

Assume the taxable component's inclusive price is ₹1,180 at model 18%, plus separate exempt consideration ₹500. Taxable base is ₹1,000, tax ₹180 and total receipt ₹1,680. Do not extract tax from the full ₹1,680.

Illustrative example 4: Two taxable rates plus exemption

Assume independent taxable lines ₹1,000 at 5% and ₹2,000 at 18%, plus exempt value ₹500. Tax is ₹50 + ₹360 = ₹410; total value before tax ₹3,500 and payable ₹3,910.

Illustrative example 5: Reconcile a batch

Ten identical correctly classified combined documents each contain taxable base ₹1,000, exempt value ₹500 and tax ₹180. Batch taxable turnover is ₹10,000, exempt turnover ₹5,000, output tax ₹1,800 and total receipts ₹16,800.

Illustrative example 6: Prevent duplicate postings

A combined document contains taxable base ₹2,000, exempt value ₹1,000 and assumed 18% tax ₹360, payable ₹3,360. Importing its exempt ₹1,000 again through another sales entry overstates total sales value by ₹1,000; it is not another underlying supply.

Ten-step verification table

StepActionEvidence
1Confirm supplier statusRegistered supplier.
2Confirm recipient statusActual unregistered recipient.
3Classify the transactionSeparate/composite/mixed-supply analysis.
4Verify rates and exemptionsOperative legal evidence.
5Choose the permitted documentRule 46A scope.
6Include required particularsRules 46/54 and 49 as applicable.
7Compute line-level amountsTaxable, exempt and tax columns.
8Reconcile inclusive pricingCorrect taxable-component extraction.
9Map ledgers and returnsSeparate compartments without duplicate sales.
10Resolve later changesEvidence and proper correction documents.

Sixteen practitioner FAQs

1. Who may use the option?

A registered supplier within rule 46A's stated circumstances.

2. Must the recipient be unregistered?

That is the stated recipient scope.

3. Can it automatically replace B2B documents?

Do not extend it beyond its wording.

4. Does it cover goods and services?

It expressly addresses goods or services or both.

5. Must taxable and exempt supplies be present?

That is the stated combination.

6. Is one combined document compulsory?

The rule permits it.

7. Does the proviso remove invoice particulars?

It preserves the stated required particulars.

8. Which bill-of-supply rule is referenced?

Rule 49.

9. What if rule 54 applies?

Review the applicable special-document particulars.

10. Does one document make a composite supply?

Classification requires its own legal analysis.

11. Can an exempt line be taxed just because the template is combined?

Apply the actual tax status, not the document layout.

12. Can tax be extracted from the entire mixed receipt automatically?

Separate the correctly established taxable-inclusive component.

13. Do model rates prove real product rates?

No. Verify actual classification and law.

14. Should exempt turnover disappear from the ledgers?

Retain the appropriate separate reporting trail.

15. Can another import post the exempt line again?

Prevent double-counting the same underlying supply.

16. What closes the reconciliation?

Line values, output tax, receipt and ledger/reporting totals agree.

Conclusion

Rule 46A permits a single invoice-cum-bill of supply for taxable and exempt supplies to an unregistered recipient. Preserve the required particulars and separate the taxable and exempt values; combining the document does not determine composite or mixed-supply classification.

Sources and primary references