Return under 148 replaces 139 Return for Penalty u/s 270 A

Section 139 pertains to the filing of a return of income by an assessee. 

section 148 deals with the issuance of a notice for reassment or re-computation of income when the Assessing Officer has reason to believe that income has escaped assessment. 

Regarding the penalty calculation under section 270A, which deals with penalty for under reporting and miscreporting of income. 

A return filed under section 148 is considered for the purpose of determining the tax liability and penalities. 

The return filed under section 148 doesn't exactly "replace" the original return filed under Section 139 in all contexts but is considered for assessing income that might have escaped assessment. 

For penalty calculations under section 270A, the comparison might involve the income assessed versus the income reported in the return filed under section 139 or as per the reassessment under section 148. 

So for penalty calculation u/s 270A,, the return filed u/s 148 doesn't simply replace the one filed u/s 139 but is part of the assessment/reassessment process. The penalty would be based on the underreported income considereing the reassessment proceedings. 

Thank you Sir for your reponse.. It solves our query. Also, we are just jotting our understanding on this  based on Eg below :

Income per Return u/s 139   - Rs.20 Lakhs

Income per Return u/s 148 - Rs. 26 Lakhs

Income assessed finally - Rs.33 Lakhs

Now penalty u/s 270 A will be charged on Rs. 7 Lakhs (Rs.33 Lakhs minus Rs. 26 Lakhs). Kindly confirm this understanding please.

@ Cindhan

Dhirajlal Ji already answered :-

Penalty would be on 13 lakhs [ 33Lakhs Final Assessment - 20Lakhs Return U/S 139]