From: Rabbi Moshe Sofer
To: Rabbi Aharon Suditz
The Chasam Sofer refutes the Pri Megadim's suggestion that performing milah shelo bizmanah on Shabbos would eliminate kareis liability. He argues that the Scriptural derivation of levado restores the full Shabbos prohibition including its lo sa'aseh, and further demonstrates from Horayos and Shevuos that kareis can attach to the asei component of a commandment independently, so that even if the lo sa'aseh were pushed aside, kareis would remain operative.
Source: Shu"t Chasam Sofer YD §251