Section 277 and 277A begins with almost similar words. In the context of section 277 Madras High Court has ruled as follows:- Section 277 uses the words ˜If a person makes" and not the words ˜If an assessee makes". Hence, section 277 applies in respect of any person and is not confined merely to an assessee. Citation:- K.V. Narasimhan v. ITO  209 ITR 797 (Mad.) Consequently,as per my understanding,in the given situation CA will be covered in section 277A.