The assessees, non-resident companies, did not initially offer secondment reimbursement receipts to tax as they were under a bona fide belief, supported by a judgment of the jurisdictional High Court and conflicting judicial precedents, that such receipts were not taxable. The receipts were duly disclosed in the tax audit report and were voluntarily offered to tax during assessment proceedings or in returns filed in response to notices under section 148. The Tribunal held that there was neither concealment of income nor furnishing of inaccurate particulars and that the assessees had acted under a bona fide belief based on prevailing legal uncertainty. Since reasonable cause existed for not offering the receipts to tax in the original returns, levy of penalty under sections 271(1)(c) and 270A was not justified. (AY. 2012-13 to 2019-20)