Reversal of credit u/s 42 on MEIS licence

Anjali Satra (CA Final Student) (25 Points)

22 February 2020  
Is there a need to reverse the credit u/s 42 of CSGT Act, 2017 for the exempted sales of MEIS Licence? Further no credit has been availed and utilised for making exempted supplies of MEIS licence as such licence is an incentive given to the exporter. Even as per section 17(2) which states that where the goods and services both are USED by registered person partly for affecting taxable supplies including zero rater supplies and partly for effecting exempt supplies, the amount of credit shall be restricted to so much as is attributable to taxable supplies and zero rated supplies. But for selling MEIS licence no credit has been availed and utilised. But the Assessing Officer has reversed the itc u/s 17(2) on the ground that the MEIS scrips are earned by the taxpayer by exporting the goods over the period of time and therefore it can be rightly said that the input goods and input services which are used for export of goods have been used by the taxpayer for earning MEIS Scrips. Kindly help me out with this as whether the contention of AO is correct or not? If not then please provide the citation on which I can refer it to AO.