Where a charitable trust had applied for registration under section 12A and, being under a bona fide belief that registration would be granted from the date of its existence, claimed exemption under section 11 for assessment year 2008-09, the Commissioner (Exemption) having subsequently granted registration with effect from assessment year 2009-10, the High Court held that the claim was based on a bona fide belief and there was no concealment of income or furnishing of inaccurate particulars of income; consequently, there was no justification for imposing penalty under section 271(1)(c). Followed,  CIT v. Reliance Petroproducts (P.) Ltd  [2010] 189 Taxman 322/322 ITR 158 (SC (AY. 2008-09).