In case of firms, who have discontinued their business still have to file return u/s 139(1), since no procedure has been prescribed
for surrender of PAN by the discontinued firms. Due to this firms are liable to penalty u/s 271F at any time.
It is suggested that procedure for surrender of PAN & exemption from filing of return of income in respect of Firms having business discontinued, may be prescribed. With this, firms may be saved from penalty u/s 271F.
Source- Pre-budget Memorandum 2014 on direct taxes by ICAI –