Penalty for Eway Bill

Yes it's treated as without Invoice,hence penalty will be imposed as per Section 129(1) of. GST it's on payment of lower of following amounts :
1. 2% of value of Goods or
2. Rs 25000/- (Total 50000/- for CGS & SGST)

Note : As he is the composition dealer & in term of rule 49 required to issue bill of supply hence no tax is charged thereon so shall be considered under Exempted goods supply & penalty shall be imposed as accordingly.