Compliance
Bill of supply for doctors: when a clinic needs one Section 31(3)(c) of the CGST Act, the particulars in rule 49, and why an unregistered clinic just issues a receipt.
"Do we need a GST bill?" comes up when a corporate patient asks for one, when the clinic starts selling a few products, or when a CA registers the clinic for some other reason. The answer depends on one fact first: whether the clinic is registered under GST. Most consultation-only clinics are not, and for them the GST invoice rules do not apply at all.
Published · Last reviewed · 5 min read
- Health care services by a clinical establishment or an authorised medical practitioner are exempt (Notification No. 12/2017-Central Tax (Rate), serial number 74). A clinic supplying only exempt services is not liable to register (CGST Act, section 23(1)(a)).
- An unregistered clinic issues no GST document. Its bill is an ordinary receipt.
- A registered clinic "supplying exempted goods or services" issues a bill of supply instead of a tax invoice (section 31(3)(c)), with the particulars in rule 49 of the CGST Rules. Below ₹200 it may skip the bill for an unregistered patient who does not want one, and issue one consolidated bill at the close of the day.
A doctor does not issue a GST tax invoice for consultation fees, because consultations are exempt. If the clinic is not registered under GST, which is the position of most consultation-only clinics, it simply gives the patient a receipt. If the clinic is registered, for example because it also sells taxable products, it must issue a bill of supply for the exempt consultation under section 31(3)(c) of the Central Goods and Services Tax Act, 2017, containing the particulars listed in rule 49 of the CGST Rules, 2017.
Is your clinic registered under GST?
Serial number 74 of Notification No. 12/2017-Central Tax (Rate), 28 June 2017, exempts "health care services by a clinical establishment, an authorised medical practitioner or para-medics". Section 23(1)(a) of the CGST Act says "any person engaged exclusively in the business of supplying goods or services or both that are not liable to tax or wholly exempt from tax" is not liable to registration. Section 22(1) makes a supplier liable only when it "makes a taxable supply" and its aggregate turnover exceeds ₹20 lakh (₹10 lakh in the special category States). Section 25(3) allows voluntary registration, after which "all provisions of this Act, as are applicable to a registered person, shall apply".
So there are two kinds of clinic for this question, and the invoice rules apply only to the second. Our post on GST on doctor consultation fees covers when a clinic crosses into registration.
| Clinic | Consultation, procedure (exempt) | Taxable product or service |
|---|---|---|
| Not registered under GST | Ordinary receipt. Section 31 and rule 49 apply to a "registered person", so no GST document is issued | If this pushes the clinic into registration, register under sections 22 and 25 first |
| Registered under GST | Bill of supply under section 31(3)(c) and rule 49 | Tax invoice under section 31 and rule 46 |
| Registered, both kinds of supply to an unregistered patient on one bill | Rule 46A allows a single "invoice-cum-bill of supply" for all such supplies |
What must a bill of supply contain?
Section 31(3)(c): "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 containing such particulars and in such manner as may be prescribed". Rule 49 lists the particulars.
| Clause | Rule 49 says | On a clinic bill |
|---|---|---|
| (a) | "name, address and Goods and Services Tax Identification Number of the supplier" | Clinic name, address and GSTIN |
| (b) | "a consecutive serial number not exceeding sixteen characters, in one or multiple series ... unique for a financial year" | Bill number restarting each April, for example SC/26-27/0001 |
| (c) | "date of its issue" | Bill date |
| (d) | "name, address and Goods and Services Tax Identification Number or Unique Identity Number, if registered, of the recipient" | Patient's name and address; GSTIN only if the payer is registered, such as a company paying for an employee |
| (e) | "Harmonised System of Nomenclature Code for goods or services" | The services code your CA uses for health care services (Heading 9993 in Notification 12/2017) |
| (f) | "description of goods or services or both" | Consultation, dressing, ECG, as itemised |
| (g) | "value of supply of goods or services or both taking into account discount or abatement, if any" | Fee after any concession |
| (h) | "signature or digital signature of the supplier or his authorised representative" | Signature; not required on an electronic bill of supply under the Information Technology Act, 2000 (third proviso) |
A bill of supply carries no tax rate or tax amount, because none is charged. The second proviso to rule 49 adds that "any tax invoice or any other similar document issued under any other Act for the time being in force in respect of any non-taxable supply shall be treated as a bill of supply".
Is a bill needed for a ₹150 consultation?
Not always. The proviso to section 31(3)(c) says "the registered person may not issue a bill of supply if the value of the goods or services or both supplied is less than two hundred rupees subject to such conditions and in such manner as may be prescribed". Rule 49 applies the provisos to rule 46 to bills of supply, and the relevant rule 46 proviso sets the conditions: the recipient "is not a registered person" and "does not require such invoice", and the supplier "shall issue a consolidated tax invoice for such supplies at the close of each day in respect of all such supplies". Read together, a registered clinic may skip the individual bill for an unregistered patient paying under ₹200 who does not ask for one, and issue one consolidated bill of supply for all such visits at the end of the day. Confirm the reading with your CA, and give a receipt to any patient who asks.
What does an unregistered clinic put on its receipt?
The GST Act sets no format, because the clinic is not a registered person. Do not print a GSTIN, the words "tax invoice" or a GST line, since none applies. What a good receipt shows for the patient, the insurer and your own books is in our post on what a clinic bill or receipt should include, and our free clinic receipt format prints one in the browser.
Check the current rule text
We read rule 49 in CBIC's consolidated CGST Rules as amended up to 1 June 2021, and the CGST Act as updated to 30 September 2020. A fourth proviso to rule 49 lets the Government require a QR code on bills of supply by notification. Ask your CA to check later notifications before you redesign a bill.
Questions
Do doctors need to issue a GST invoice?
No. Consultations are exempt under serial number 74 of Notification 12/2017-Central Tax (Rate). An unregistered clinic issues an ordinary receipt. A registered clinic issues a bill of supply under section 31(3)(c) of the CGST Act for the exempt service, and a tax invoice only for any taxable sale.
What is the difference between a bill of supply and a tax invoice?
A tax invoice (section 31 and rule 46) shows the rate and amount of tax on a taxable supply. A bill of supply (section 31(3)(c) and rule 49) is issued for exempt supplies and carries no tax.
Can one bill cover a consultation and a taxable product?
Yes, for a patient who is not GST-registered. Rule 46A allows a single "invoice-cum-bill of supply" where a registered person supplies taxable and exempted goods or services to an unregistered person.
Sources
- CBIC, The Central Goods and Services Tax Act, 2017 (updated up to 30 September 2020): sections 22, 23, 25 and 31 (accessed 30 Oct 2026)
- CBIC, Central Goods and Services Tax Rules, 2017, Part A (as amended up to 1 June 2021): rules 46, 46A and 49 (accessed 30 Oct 2026)
- Ministry of Finance, Notification No. 12/2017-Central Tax (Rate), 28 June 2017, serial number 74 (accessed 30 Oct 2026)
This is operational guidance for clinics, not legal or tax advice. Confirm with your state authority, council or CA.
Drafted with AI assistance; every fact checked against the sources listed; reviewed by the Vitels team.