2026 (1) TMI 940

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....dv For the Revenue : Shri M.S. Nethrapal, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The Assessee LL Global Inc. (hereinafter referred to as 'assessee) by filing the present appeal sought to set aside the impugned order dated 26.03.2024 for AY 2016-17 and 2017-18 passed by the Assessing Officer (AO) under section 147 r.w.s. 144C of the Income Tax Act, 1961 (for short 'the Act') inconson....

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.... company providing services by way of offering LOMA (Course Enrollment) and LIMRA offerings. LOMA courses are self-paced courses for the employees of the purchasing company whereas LIMRA offerings provide reward and recognition professional development programs that offer customers the ability to formally recognize their top performers with differing levels of certification, thereby achieving mast....

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....itted that the escapement of income for both the years under consideration is less than Rs 50 lakhs even according to the ld AO while recording the reasons. 4. Admittedly the 1st notice u/s 148 of the Act dated 25-6-2021 has been issued beyond the period of 3 years from the end of the relevant assessment year. Hence as per the amended provisions of section 149 of the Act, notice u/s 148 of the ....