What details must a retailer's sales tax invoice contain?

A sales tax invoice has a fixed list of contents set by section 23 of the Sales Tax Act, 1990. The list applies to every registered person making a taxable supply, including a registered retailer, and the Finance Act, 2026 added a requirement for a verifiable FBR invoice number.

What does the law say?

Section 23(1), as amended by section 4 of the Finance Act, 2026, requires a registered person making a taxable as well as exempt supply to issue a tax invoice, including an advance receipt invoice, bearing a verifiable and unique FBR invoice number, at the time of supply. The particulars must be in Urdu or English. (The consolidated text still prints the older wording, “serially numbered tax invoice”, next to the new words. Section 4 of the Finance Act, 2026 shows that the new expression replaced it.)

The invoice must contain:

Clause	Particular
(a)	Name, address and registration number of the supplier
(b)	Name, address and registration number of the recipient; for supplies by a manufacturer or importer to an unregistered distributor, the NIC or NTN of that distributor
(c)	Date of issue
(d)	Description and quantity of goods (with count, denier and construction for textile yarn and fabric)
(e)	Value exclusive of tax
(f)	Amount of sales tax
(g)	Value inclusive of tax

The provisos add that:

• the Board may notify persons allowed to issue an advance receipt invoice within the notified system;
• the FBR invoice number condition applies from the time the Board notifies;
• the Board may specify modified invoices for different persons or classes;
• not more than one tax invoice shall be issued for a taxable supply;
• where goods are transported, the invoice must be linked with the e-Bilty (the digital transport document).

Section 23(2) says only a registered person or a person paying retail tax may issue an invoice under this section.

How does it work for a retailer selling to walk-in customers?

Clause (b) asks for the recipient’s name, address and registration number. A walk-in customer usually has no registration number. The consolidated text keeps an Explanation defining “ordinary consumer” as a person buying goods for his own consumption, not for resale or processing, but the provision that used the term is not visible in the current wording. The Act’s answer here is the power to specify modified invoices by notification. Any such notification for retailers is not held in this corpus, so the exact customer details a retail invoice needs cannot be confirmed from the Act alone.

For Tier-1 retailers, the proviso to section 23(6) requires integration of retail outlets with the Board’s computerized system for real-time reporting of sales, from the date and in the manner the Board prescribes. Section 23(5) lets the Board require any person or class to integrate its electronic invoicing system.

What records does a registered retailer keep?

Section 22(1) requires a registered person making taxable supplies to keep records, in English or Urdu, at the business premises or registered office. They include records of supplies showing description, quantity, value, the buyer’s name and address and the tax charged; records of purchases with the supplier’s registration number; double entry sales tax accounts; invoices, credit and debit notes, bank statements, inventory records, utility bills, salary bills, cash book and rental agreements; and electronic versions of these. A proviso says persons paying retail tax keep such record as the Board specifies. Section 24 requires records to be retained for six years after the end of the tax period.

Worked example (illustrative figures)

A registered Tier-1 store in Lahore sells two cotton bedsheets at Rs. 2,000 each. For this example, assume they are taxed at the general rate of eighteen percent in section 3(1).

1. Value exclusive of tax: 2 x Rs. 2,000 = Rs. 4,000.
2. Sales tax: 18% x Rs. 4,000 = Rs. 720.
3. Value inclusive of tax: Rs. 4,000 + Rs. 720 = Rs. 4,720.

The invoice should show the store’s name, address and registration number, the date, “Bedsheet, cotton, 2”, Rs. 4,000, Rs. 720 and Rs. 4,720, plus the FBR invoice number once that condition is in force.

If the store failed to issue an invoice for this sale, serial 2 gives 5% x Rs. 720 = Rs. 36, which is lower than Rs. 25,000, so the penalty is Rs. 25,000. On sales with tax involved of Rs. 1,000,000, 5 percent is Rs. 50,000, which is higher, so the penalty is Rs. 50,000.

What if the retailer does not keep records?

Serial 8 of the section 33 table covers any person who fails to maintain records required under the Act or rules. The penalty is Rs. 50,000 or 5 percent of the amount of tax involved, whichever is higher.

Common mistakes

• Showing only a tax-inclusive total. Clauses (e), (f) and (g) require the value before tax, the tax and the value after tax as three separate figures.
• Issuing two invoices for one sale. A proviso to section 23(1) allows only one.
• Assuming a small retailer on the electricity bill route issues tax invoices. Section 23(2) limits invoices to registered persons and persons paying retail tax.

What to check in the official text

Read sections 22, 23 and 24 and serials 2 and 8 of the section 33 table in the Sales Tax Act as amended to 30 June 2026, and section 4 of the Finance Act, 2026 for the new invoice wording. Check the Board notifications on the FBR invoice number start date, modified invoices for retailers and the integration date for Tier-1 retailers. These are not held here.