ITAT upheld the reopening of assessment under section 147,...

ITAT upheld the reopening of assessment under section 147, finding no true and full disclosure of necessary facts regarding interest income from Mexican subsidiaries. The tribunal rejected the assessee's arguments about inventory valuation, ruling that provisions for inventory loss must be added back to book profit under section 115JB(2). The key issue centered on incomplete reconciliation of interest income and improper accounting treatment of inventory provisions. The tribunal determined that the Assessing Officer validly reopened the assessment due to escaped income, specifically noting discrepancies in interest income reporting and inventory valuation methodology. Consequently, the assessee's appeal was dismissed, affirming the lower authorities' computational adjustments.