Barcode : 4326250-02 A-533-889 REV - Admin Review 12 / 13 / 19 - 5 / 31 / 21
information had been correctly reported and , thus , requested clarification . 130 In addition , Commerce asked a series of questions about the various product characteristics that were reported , noting that a number of the items reported had errors ( e . g ., thickness , field THICKU ), were incorrectly coded ( e . g ., slab size , field SIZEU ), or were not reported as instructed by Commerce ( e . g ., design , field DESIGNU ). 131 CONNUMs are used to compare sales in the U . S . market to those made in the home market ; it is this matching process that is the basis for the margin calculations . Thus , without the information requested in the supplemental questionnaire regarding Antique Group ’ s initial reporting of product codes and product characteristics , Commerce cannot conclude that Antique Group ’ s CONNUMs were correctly reported . In fact , based on the information requested in the supplemental questionnaire , the record is clear that Antique Group ’ s initial reporting of the CONNUM fields in the U . S . sales data was incorrect and , were we to use that data , we would be calculating a margin that is demonstrably inaccurate .
In addition to issues undermining the accuracy of the comparison of sales data and whether all U . S . sales have been reported , Commerce also identified other issues that result in questions about the fundamental reliability and accuracy of the initial U . S . data . 132 For example , Commerce flagged issues with the unit of measure for the quantity in which the U . S . sales were reported . In order to conduct an accurate margin analysis , Commerce must conduct an “ applesto-apples ” comparison by ensuring that all of the reported data is compared on the same basis ( e . g ., square meter , metric ton ). Any margin results are meaningless where Commerce cannot be confident that the quantities of the sales were reported on the same unit of measure . Further , Commerce noted that , based on the statements by Antique Group in the initial questionnaire response , the record is unclear as to in which currency the U . S . sales prices had been reported and that it appeared that prices were possibly reported incorrectly . 133 If Commerce is to carry out a margin analysis , which is based on prices , there cannot be any question as to in which currency the sales were reported or whether the prices were correctly reported .
In addition , Antique Group ’ s statements in its initial questionnaire response regarding adjustments and discounts to prices did not align with the data provided to Commerce , again indicating that Antique Group ’ s responses contained discrepancies that did not allow for us to fully understand whether price adjustments and discounts were correctly reported . 134 As these fields also play a role in determining the price used in the margin calculations , to the extent Commerce had identified unresolved discrepancies , we cannot conclude that the information was reliable or would have resulted in an accurate margin calculation .
Another key part of any margin analysis is whether expenses are correctly reported . The second supplemental questionnaire flagged a variety of issues and discrepancies with reported freight costs , loading charges , brokerage and handling fees , credit expenses , other direct selling expenses , inventory carrying costs , and packing expenses . 135 In effect , nearly all reported expenses had some sort of discrepancy or issue with them , which means that Commerce has no
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29 Filed By : David Lindgren , Filed Date : 1 / 3 / 23 1:27 PM , Submission Status : Approved