Tribunal held that  though, assessee had not challenged addition made by AO in quantum proceedings, it did not ipso facto follow that penalty for concealment or furnishing of inaccurate particulars could be imposed.  The assessee had offered explanation and the submissions as to why receipts were not offered to tax for the year under consideration, by relying on the legal position. Assessee had acted in a bona fides manner and had also furnished all material facts and particulars in respect of the same. Levy of penalty is held to be not justified.(AY. 2010-11)