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If you sell goods online without GST registration, give the customer a regular commercial invoice or bill—not a GST tax invoice—and do not show GST as a separately collected amount. Whether you may sell without registering is a separate question: the conditional exemption for certain goods sellers using e-commerce operators (ECOs) requires you to stay within the applicable turnover threshold, make only intra-State supplies, complete the required portal enrolment, and meet every other condition in Notification 34/2023-Central Tax. It has applied since 1 October 2023.
The document you send and your eligibility to remain unregistered are connected, but they are not the same issue. An accurate invoice cannot cure an ineligible selling arrangement. Check the route, destination State or Union territory, turnover and enrolment status before accepting orders, then keep a record that allows every invoice to be matched to payment, dispatch, delivery, returns and marketplace settlement.
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Can you sell online without GST registration?
Some sellers of goods can use a conditional registration exemption, but it is not a general exemption for every online business. Notification 34/2023-Central Tax, issued on 31 July 2023 and effective from 1 October 2023, covers eligible persons supplying goods through an ECO, subject to the applicable section 22 turnover threshold and the notification’s conditions.
In particular, the seller must not make inter-State supplies, must not use an ECO to make supplies in more than one State or Union territory, and must complete the prescribed enrolment before supplying goods through the operator. The GST Council’s meeting record describes the 2023 changes as a waiver and special procedure for certain unregistered goods suppliers and composition taxpayers using ECOs.
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Check the threshold that applies to your business and State or Union territory under current rules; do not assume that one national figure applies to every seller. The figures sometimes quoted for service suppliers are not a substitute for checking the threshold applicable to a goods seller. Product-specific restrictions, later amendments, and the platform’s current seller policy also matter.
For example, a seller located in one State who sells only goods delivered to customers in that same State may be able to examine the notification. The same seller cannot simply keep using the workflow after accepting an order that is an inter-State supply. A change in the checkout settings, warehouse, delivery destination or marketplace account can therefore change the GST analysis even if the product and price stay the same.
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- Keep aggregate turnover within the applicable registration threshold.
- Make no inter-State supplies of goods.
- Use an ECO for supplies in no more than one State or Union territory.
- Have a PAN and declare it, your business address, and the intended State or Union territory on the common portal.
- Complete the required validation and obtain an enrolment number.
- Do not make supplies through the ECO before the enrolment number is granted.
These conditions are cumulative. Treat the exemption as unavailable until you have checked that your particular business and selling route satisfy all of them. Keep evidence of the checks: a turnover spreadsheet, the declared business address, enrolment confirmation, order destinations and the operator’s reports.
What should an invoice look like if you do not have a GSTIN?
Issue a clear commercial invoice or bill for each order. Identify the document as “Invoice” or “Bill,” not “GST Tax Invoice”; show the sale details and the amount payable, but do not add a GST rate or a separately collected GST amount.
Section 31 of the CGST Act requires a registered person making a taxable supply of goods to issue a tax invoice. Rule 46 sets out particulars for that registered-person tax invoice, including the supplier’s GSTIN. Those provisions explain why an unregistered seller’s customer document should be presented as a commercial sales record rather than as a GST tax invoice. Do not suggest that it entitles the buyer to input-tax credit.
Do not copy a registered seller’s template and merely leave the GSTIN blank. A heading such as “Tax Invoice,” a column marked “CGST/SGST,” or a line saying “GST included” can make the document appear to collect tax. If you are not registered and have not charged GST, the total should be the commercial amount agreed with the customer, including any disclosed delivery charge.
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Useful fields for a commercial invoice
- Seller’s name and business address.
- Buyer’s name and delivery address.
- A unique invoice or order number and the issue date.
- Product description, quantity, unit price, and any discount.
- Shipping or delivery charge, if charged, and the total amount paid or due.
- Payment method and payment status.
- Return terms or a reference to the applicable return policy.
These fields make the transaction understandable to the customer and easier to reconcile later. They are practical commercial-document fields, not a claim that an unregistered seller must reproduce every Rule 46 tax-invoice particular.
Use a sequential numbering convention that you can explain, such as 2026-0001, 2026-0002 and so on, or a separate series for each sales channel. Avoid reusing a number after a cancellation. If an order is refunded, retain the original invoice and link the refund record to it rather than silently deleting the sale from your files.
Simple layout you can adapt
Invoice
Seller: [business name and address]
Buyer: [customer name and delivery address]
Invoice/order number: [unique number]
Date: [issue date]
Items: [description, quantity, unit price, discount]
Delivery: [charge, if any]
Total: [amount paid or due]
Payment status: [paid or due]
Returns: [return terms or policy reference]
You may add a plain-language note such as “Seller is not GST-registered; no GST has been charged” to make the document’s status clear. Do not present that note as a substitute for checking whether you are eligible to remain unregistered. If the marketplace generates a customer document, review its heading and tax fields and use a separate commercial invoice when necessary to avoid an inaccurate GST representation.
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How do you prepare and send an invoice for each order?
Use a consistent process: confirm the selling route and eligibility first, complete required enrolment before supplying through a qualifying ECO, then issue and retain a commercial invoice for every order.
- Check eligibility before accepting orders. Confirm the current threshold for your State or Union territory, ensure your planned goods sales will be intra-State, and ask the ECO whether it supports the unregistered-seller enrolment procedure. Check the destination shown at checkout rather than relying only on your business address.
- Complete portal enrolment before supplying through the ECO. Declare your PAN, business address, and intended State or Union territory on the common portal. Wait until the enrolment number is granted; Notification 34/2023 says no supply through the ECO may be made before then. Save the confirmation and the date on which it was issued.
- Configure the sales channel. Set the marketplace or checkout to the permitted State or Union territory, and confirm that shipping rules cannot silently accept an inter-State destination. If the platform cannot restrict destinations, ask how it treats an order that crosses a State boundary before listing products.
- Create an invoice or bill for the order. Use a unique number and date, identify the seller and buyer, list the goods and amounts, and show the final total and payment status. Keep the label “Invoice” or “Bill”; do not label it a GST tax invoice or break out GST as though you collected it.
- Send it with the order confirmation or fulfilment communication. Make sure the customer can identify which order the document relates to and where the goods were delivered. A PDF, printed bill or platform document can work as a commercial record if the information is complete and legible.
- Keep a matching order file. Retain the invoice with the order confirmation, payment settlement, shipping proof, return or refund details, and marketplace report. Use those records to reconcile sales and monitor turnover and eligibility conditions.
- Reassess before changing how you sell. Get advice before shipping to another State, using an ECO in a second State or Union territory, or making another change that may affect the exemption.
Worked example
Suppose a seller lists a ₹1,499 product, gives a ₹100 discount and charges ₹60 for delivery. The commercial invoice can show the item at ₹1,499, the discount of ₹100, delivery of ₹60 and a total of ₹1,459. It should not add a separate GST line or describe the ₹1,459 as “including GST.” If the customer pays online, mark the invoice “Paid”; if payment is due on delivery, mark it “Due” and update the internal order record when the payment is received. The figures are only an illustration of presentation, not a prescribed tax calculation.
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Does the rule work the same on your own site and on a marketplace?
No single online-sales route should be assumed to qualify automatically. The notification concerns eligible goods supplied through a qualifying ECO; the platform, geography, enrolment process, settlement method, and your business model all affect what you need to check.
| Issue | Your own site or social channel | Marketplace or other ECO |
|---|---|---|
| What to verify | Establish how the sales route is treated for GST purposes and whether the notification’s ECO conditions apply to it. Do not assume that selling online directly either qualifies or is excluded. | Confirm the operator supports the required enrolment process and that your use of it stays within the notification’s State or Union territory condition. |
| Geography | Check the origin and destination of every goods supply; the exemption requires no inter-State supplies. | Check delivery destinations and how the operator handles orders across State or Union territory boundaries; the same no-inter-State condition applies. |
| Order and payment records | Keep your order, payment, delivery, and refund records together. | Reconcile platform orders and settlement reports to returns, refunds, and any TCS entries. |
| Invoice | Provide a commercial invoice or bill for the sale, without presenting it as a GST tax invoice. | Provide a commercial invoice or bill for the sale; the platform’s own onboarding or document workflow may differ. |
| Platform availability | Not applicable in the same way; you control the site or channel, but still need to confirm the legal treatment of the route. | Do not assume every marketplace accepts unregistered sellers; check its current seller policy and onboarding requirements. |
The table is a practical checklist, not a ruling that every website or social channel has the same legal status. The notification’s exemption is specifically conditional; it does not establish a blanket exemption for every online business model.
Direct checkout also requires careful destination controls. A customer placing an order from another State, a drop-shipper dispatching from a different State, or a fulfilment warehouse moving stock across a State boundary can create facts that differ from the seller’s original plan. Pause the order and obtain advice rather than editing the invoice to conceal the destination.
What is marketplace TCS, and should it appear on your invoice?
Marketplace tax collected at source (TCS) is an operator-side collection and settlement item, not GST that an unregistered seller should list as a tax charged to the customer on the seller’s commercial invoice. Reconcile the operator’s settlement report with the orders, returns, and TCS entries instead.
The GST Council Law Committee FAQ updated on 30 November 2018 describes TCS as an amount collected by an ECO on the net value of taxable supplies when the operator collects the consideration. That FAQ gives a notified structure of 0.5% CGST plus 0.5% SGST or UTGST for intra-State supplies, or 1% IGST. Because that FAQ is dated 2018, check current rules and the operator’s settlement reporting rather than treating those figures as confirmation of the rate that applies to a present transaction.
For illustration, on a ₹10,000 intra-State taxable-supply value, a 0.5% plus 0.5% structure would total ₹100 in operator-collected TCS. That amount may reduce the settlement paid to the seller; it does not turn the seller’s invoice into a GST tax invoice. Use the platform statement to identify the exact orders, cancellations and refunds included in the calculation.
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Do not add a marketplace TCS amount to the customer-facing invoice as though you collected GST from the buyer. Keep the platform report with the order file so that the settlement can be matched to actual orders and subsequent returns or refunds.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.When should you stop using the no-registration workflow?
Recheck eligibility before an operational change, not only when preparing an invoice. Inter-State goods sales, using an ECO in another State or Union territory, turnover above the applicable threshold, or failure to maintain the required enrolment can mean the exemption no longer applies.
- Before shipping across a State boundary: stop and confirm the consequences; the notification requires that an eligible person make no inter-State supply of goods.
- Before adding another ECO or territory: check whether the arrangement would mean using an ECO in more than one State or Union territory.
- As turnover approaches the threshold: track aggregate turnover and verify the current threshold and registration timing for your circumstances. Do not wait for a marketplace dashboard to alert you.
- If enrolment or business details change: confirm that your portal status and declarations still meet the prescribed procedure.
- If the business starts supplying services or changes products: do not assume the goods-seller exemption covers the changed activity; check the rules that apply to it.
- If the platform changes its policy: review new onboarding, settlement or invoice requirements before relisting products.
If a condition is no longer met or you are uncertain whether it applies, seek advice from a GST professional before taking more orders under the unregistered workflow. The 2023 notification and the GST Council guidance do not replace checking later amendments, State or Union territory thresholds, product-specific restrictions, and the platform’s current policy.
Common mistakes to avoid
- Calling the document a tax invoice: use “Invoice” or “Bill” and remove GST-rate and GST-amount columns.
- Showing GST as included: if no GST was charged, do not imply that the customer paid GST or can claim input-tax credit.
- Using the enrolment number as a GSTIN: an enrolment number obtained under the notification does not turn an unregistered seller into a registered supplier. Follow the operator’s instructions for displaying it, if any.
- Accepting an inter-State order accidentally: destination controls and a manual review of exceptions are essential.
- Ignoring returns: preserve the original invoice and link every refund, replacement or cancellation to the original order.
- Assuming TCS is customer GST: TCS belongs in the marketplace settlement reconciliation, not as a tax line on the seller’s invoice.
- Relying on a platform’s template: marketplace-generated documents may contain fields intended for registered sellers; review them before sending them to customers.
Frequently Asked Questions
Can I use the goods-seller exemption for online services too?
Do not assume so. Notification 34/2023-Central Tax addresses qualifying supplies of goods through an ECO; a service business needs to check the registration rules applicable to its own supplies.
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Does my enrolment number have to be printed on the customer invoice?
The notification requires the enrolment number before making supplies through the ECO, while the tax-invoice particulars in Rule 46 concern registered suppliers. The notification does not establish a separate customer-invoice field requirement for an unregistered seller, so check the operator’s current document instructions.
What if a marketplace says it does not onboard sellers without a GSTIN?
Do not treat the notification as a promise that every platform must accept an unregistered seller. Check the marketplace’s current seller policy and onboarding route; if that platform will not onboard you, do not submit a GSTIN you do not have or begin supplying through it before resolving your registration position.
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Can I charge GST if I am not registered?
No. Your customer-facing commercial invoice should not show a GST rate or separately collected GST amount. Charging or representing GST as tax is different from stating the total commercial price.
Can my customer claim input-tax credit from my invoice?
An unregistered seller’s commercial invoice is not the registered-person tax invoice contemplated by section 31 and Rule 46. Do not promise the customer an input-tax credit.
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Possibly, only if your goods-selling arrangement meets every condition of Notification 34/2023-Central Tax and the marketplace accepts the required enrolment route. The notification does not require every marketplace to onboard unregistered sellers, and you must not make inter-State supplies.
What happens if my turnover crosses the threshold?
Stop treating the exemption as automatic and verify the registration requirement and timing for your State or Union territory. Keep invoices and order records so the point at which turnover changed can be identified accurately.
Should TCS be deducted from the amount on my invoice?
No. Show the customer the commercial total agreed for the order. Reconcile any operator-collected TCS in the marketplace settlement report; do not present it as GST charged by you.
Do I need a separate invoice for a returned order?
Keep the original invoice and attach the return, refund or replacement record. Your files should show the link between the original sale and its adjustment; do not erase the original document.
The Bottom Line
Use a plainly labelled commercial invoice or bill, show the full sale details and no separately collected GST, and retain an order file for every transaction. Before selling through an ECO without registration, confirm the current threshold, intra-State-only geography, single-State/Union-territory ECO condition, PAN declaration and enrolment number. Recheck the position before any inter-State sale, expansion or business-model change.
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