NetSuite is somewhat inconsistent. I believe the underlying value in the database may be 'T' or 'F'. Even in SS2.0 you get 'T' or 'F' when you run a search and you need to use 'T' or 'F' to set the default value of a fields that you create and add to forms / suitelets.
Because the return of a workflow action script provides its value to something that isn't SS2.0, I would bet that you need to return 'T' or 'F'.