Tax invoice or bill of supply

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:

Section 2(47) “exempt supply” means supply of any goods or services or both which
attracts nil rate of tax or which may be wholly exempt from tax under section 11, or
under section 6 of the Integrated Goods and Services Tax Act, and includes
non-taxable supply;

Now my question is if a registered person supplies nil-rated goods what will he issue - Tax invoice or Bill of Supply.

Section 31(3)(c) tells him to issue Bill of Supply in case of exempted goods.

Nil rated supply form part of term 'exempt supply' but section 31(3)(c) talks about 'exempted goods' and NOT 'exempt supply'.

The poin to consider here is that exempted goods means only those goods which are specified by a notification to be exempt or does it also include nil-rated goods?

the law does not give definition of "exempted goods".

In my view a Tax Invoice should be issued by a registered person if he supplies only nil-rated goods to a recipient, as i feel nil-rated goods are not exempt goods though they form part of 'exempt supplies'.

Please suggest.

regards

shivani