Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealment.

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....Penalty under 271(1)(c) was held unsustainable where the assessee filed the tax audit and disclosed financial statements timely, offered the entire income voluntarily after a section 148 notice which was accepted without additions, and discharged tax liability before completion of assessment; these facts supported negligence or inadvertence rather than an intent to conceal, so reasonable cause for non-filing under section 139(1) was established and the deeming fiction in Explanation 3 could not be invoked mechanically. Penalty initiation lacked linkage to any specific concealment or inaccurate particular.....