Unregistered GST provider using own truck for transport can issue Form 2.1 as a consignment note u/r 4B.

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....Classification of services - GTA services - person unregistered with GST, providing road transport services by his own truck - issuance of E-way bill - consignment note' has not been defined in the Act or in the Notification either. In this context we take the help of Explanation to Rule 4B of Service Tax Rules, 1994 wherein the ''consignment note' has been defined as a document provided by a goods transport agency against the receipt of goods for the transport of goods by roadways in a goods carriage. - Form 2.1 may be treated as consignment note, thus the condition of OTA is fulfilled.....