Barcode : 4326250-02 A-533-889 REV - Admin Review 12 / 13 / 19 - 5 / 31 / 21
basis to conclude that a significant portion of expenses were reliably reported . Given that expenses are used to ensure that U . S . prices are correctly compared to normal values ( from home market data ), any unresolved discrepancies means that Commerce is unable to conclude that a dumping margin calculated based on those expenses would be an accurate reflection of the selling behavior of Antique Group in the United States .
Moreover , Commerce noted that there were issues with the reported destination information ; this information is used in Commerce ’ s differential pricing methodology to determine whether there are patterns of pricing that may affect the way the margin calculations are conducted . 136 Thus , to the extent that this information is also unresolved , Commerce cannot be confident that it is able to evaluate the full extent of any dumping across regions , periods , or customers . 137
In addition to the significant and unresolved issues related to Antique Group ’ s U . S . sales data , Commerce also identified a number of issues with the cost of production ( COP ) data . The COP data are used by Commerce to determine whether or not home market sales were made above COP . If home market sales are made below COP , then Commerce may need to remove these sales from the analysis when calculating the normal value ; an accurate normal value is important because it is what the U . S . sales data are compared to when ultimately calculating a margin . Thus , just as it is necessary that U . S . sales data be accurate , the COP data should also be accurate to ensure that the correct pool of home market sales are used to calculate normal value . The second supplemental questionnaire included a number of questions relating to issues with the COP data , including deficiencies that required revisions to be made to the data that had been reported ( e . g ., revising issues with the CONNUMs in the cost database , how raw material costs were calculated , issues with various overhead costs , identification and reporting of research and development expenses ). 138 In addition , the issues with CONNUMs described above also impact the cost data as well as the U . S . sales data , meaning that the initial COP data appear to have calculated the costs based on incorrect CONNUMs , which would mean that the cost data would not be correctly matched to home market sales . As a result , Commerce has no basis upon which to conclude that any of the COP data submitted in the initial questionnaire responses by Antique Group is reliable or would result in an accurate dumping margin .
Finally , Antique Group asserts that the supporting documentation requested by Commerce is immaterial to whether an accurate dumping margin is calculated . We strongly disagree with this argument , as supporting documentation is an essential aspect of Commerce ’ s ability to ensure that it is calculating an accurate margin . Commerce not only requires that respondents submit data on their sales and costs , but also requires that respondents demonstrate that this data is accurate . We do not engage in requests for supporting documentation simply for the purpose of collecting information , but rather , this information serves the purpose of permitting Commerce to evaluate whether the data has been correctly reported . In a number of instances in the second supplemental questionnaire , Commerce noted that the supporting documentation provided in Antique Group ’ s initial questionnaire responses indicated discrepancies in the data , that Antique Group had stated it had provided supporting documentation for something but failed to do so , or that Commerce asked for further supporting documentation to evaluate whether the reported data
136
Id . at 11 .
137
See , e . g ., Preliminary Results PDM at “ VII . B . Comparison of Normal Value .”
138
See Antique Group Second Supplemental Questionnaire at 14-17 .
30 Filed By : David Lindgren , Filed Date : 1 / 3 / 23 1:27 PM , Submission Status : Approved