When order in quantum has been decided in favour of assessee penalty cannot be levied u/s 271(1)(c)

Brief Facts The assessee, an educational society, filed its Income tax Return at a Nil income being exempt u/s 10(23C)(iiiad). The assessment in this case was completed in the status of AOP u/s 143(3) / 147 and certain additions were made in the assessment order passed. Thereafter, AO also imposed penalty u/s 271(1)(c) on the ground of furnishing of inaccurate particulars of income. Tribunal had deleted the additions made in the assessment order passed u/s 143(3) / 147 and Deptt went in the High Court against the order of Tribunal Decision by Delhi Tribunal As this appeal was filed by Revenue...