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21. Thus, it is clear that when the A.O. has accepted the revised return filed by the assessee under Section 153A, no occasion arises to refer to the previous return filed under Section 139 of the Act. For all purposes, including for the purpose of levying penalty under Section 271(1)(c) of the Act, the return that has to be looked at is the one filed under Section 153A........."

5.In the case of ACIT, Central Circle -1(3), Chennai Vs. V.N. Devadoss [2013] 32 taxmann.com 133 (Chennai - Trib.) Hon'ble ITAT Chennai Bench has held that the returns filed by the assessee under Section 153A are to be treated as returns filed under Section 139(1) by virtue of the law stated in Section 153A(1)(a). We quote from the head notes as under:-

9.1 We note that Ld. Counsel of the assessee also relied upon the decision of Hon'ble Bombay High Court in the case of CIT vs B.G Shirke Construction Technology Pvt Ltd [2017] 79 taxmann.com 306 (BOM) and of Chennai ITAT in the case of ACIT, Central Circle - 1(3), Chennai Vs. V.N. Devadoss [2013] 32 taxmann.com 133 wherein claim of deduction made for the first time in 153A return was duly allowed holding that returns filed by the assessee under Section 153A are to be treated as returns filed under Section 139(1) by virtue of the law stated in Section 153A(1)(a). The said two decisions also support the assessee's case that the return u/s 153A is to be treated as return filed u/s 139(1). In the case of V.N Devadoss (supra), deduction claimed u/s 80-IB in return filed u/s 153A was allowed even though such deduction was not claimed in a return filed u/s 139(1).