No penalty on NR for wrongly claiming exemption u/s 10(8A) for technical services under bona-fide be

IT : Where assessee received certain amount from Asian Development Bank for rendering engineering consultancy services, in view of fact that assessee was under a bona fide belief that said amount was exempt from tax in terms of agreement between parties and having regard to obligation of Government to bear tax on behalf of assessee, AO could not pass penalty order under section 271(1)(c) taking a view that amount in question was taxable in assessee's hands