Question

Whether an Unregistered person can issue “Bill of Supply” ? In fact what should be the heading of commercial document to be issued by Unregistered person (akin to Tax Invoice for Registered Person) ?

Answer

Facts of the case:
Unregistered person wants to issue a commercial document at the time of sale. Whether the same can be a Bill of Supply.

Law Applicable:
As per section 31(3)(c) CGST
"a registered person supplying exempted goods or services or both or paying tax under the provisions of section 10 shall issue, instead of a tax invoice, a bill of supply..."

Interpretation:
The act is abundantly clear in making the registered person liable to make an exempt supply under the cover of Bill of Supply. Therefore an unregistered person can not be held liable to draw a Bill of Supply for each and every sale made by them.
When a person is unregistered they stand outside the purview of the act and hence can not be governed by the corresponding rules etc.

Conclusion:
Since the act is not applicable on a unregistered person therefore legally they are not bound to draw a Bill of Supply. Practically an unregistered person may simply make their sales under a cover of Invoice (not Tax Invoice) and he is not bound with the format of invoice required under GST Laws  (Reply dt.22/04/2019)