Penalty u/s. 271F for failure to furnish return u/s. 153A

From a bare reading of section 139 and 153A, it is evident that the provisions of section 271F are attracted when a person is required to furnish the return in accordance with section 139(1) or by provisos of that section. Section 153A starts with non-obstante clause and the purpose is only to specify separate time limit for filing the return.

The only distinction in section 153A is that the AO is required to issue notice to the assessee requiring him to furnish the return within such period, as may be specified in notice, but

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