Full opinion text
OPINION TSOUCALAS, Senior Judge. Plaintiffs and defendant-intervenors, NTN Bearing Corporation of America, American NTN Bearing Manufacturing Corporation and NTN Corporation (collectively “NTN”), NSK Ltd. and NSK Corporation (collectively “NSK”), and Koyo Seiko Co., Ltd. and Koyo Corporation of U.S.A. (collectively “Koyo”), move pursuant to USCIT R. 56.2 for judgment upon the agency record challenging various aspects of the Department of Commerce, International Trade Administration’s (“Commerce”) final determination, entitled Final Results of Antidumping Duty Administrative Reviews of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From Japan, and Tapered Roller Bearings, Four Inches or Less in Outside Diameter, and Components Thereof, From Japan (“Final Results”), 63 Fed.Reg. 2558 (Jan. 15, 1998), as amended, Amended Final Results of Anti-dumping Duty Administrative Reviews of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From Japan, and Tapered Roller Bearings, Four Inches or Less in Outside Diameter, and Components Thereof, From Japan (“Amended Final Results ”), 63 Fed.Reg. 13,391 (Mar. 19, 1998). Defendant-intervenor and plaintiff, The Timken Company (“Timken”), also moves pursuant to USCIT R. 56.2 for judgment upon the agency record challenging certain determinations of Commerce’s Final Results. Specifically, NTN contends that Commerce unlawfully: (1) conducted a duty absorption inquiry under 19 U.S.C. § 1675(a)(4) (1994) for the 1976 antidump-ing duty order; (2) denied a price-based level of trade (“LOT”) adjustment for NTN’s constructed export price (“CEP”) sales; (3) rejected NTN’s allocation of United States and home market selling expenses on an LOT-speeific basis; (4) refused to calculate CEP profit on an LOT-specific basis; (5) included export price (“EP”) sales in the calculation of CEP profit; (6) recalculated NTN’s credit expenses on a transaction-specific basis; (7) denied a downward adjustment to NTN’s reported United States indirect selling expenses for imputed interests incurred in financing cash deposits for anti-dumping duties; (8) adjusted NTN’s cost of production (“COP”) and constructed value (“CV”) for affiliated party inputs; (9) applied a 99.5% test to determine whether sales to NTN’s affiliated parties were made at arm’s length; (10) double-counted NTN’s depreciation of idle equipment; (11) included its zero-priced United States transactions in the margin calculations and failed to exclude NTN’s sample sales and other sales from its margin calculation; and (12) used facts available to adjust NTN’s reported billing adjustment. NSK contends that Commerce unlawfully; (1) conducted a duty absorption inquiry under 19 U.S.C. § 1675(a)(4) for the 1976 and 1987 antidumping duty orders; (2) used NSK’s affiliated supplier cost data to run its model match methodology under 19 U.S.C. § 1677(16) (1994), to calculate the difmer adjustment under 19 U.S.C. § 1677b(a)(6) (1994) and to recalculate NSK’s reported U.S. inventory carrying costs (“ICC”) prior to deducting this expense from CEP pursuant to 19 U.S.C. § 1677a(d) (1994); and (3) denied a partial LOT adjustment. Koyo contends that Commerce unlawfully: (1) conducted a duty absorption inquiry under 19 U.S.C. § 1675(a)(4) for the 1976 and 1987 antidumping duty orders; (2) applied adverse facts available to Koyo’s sales of further manufactured tapered roller bearings (“TRBs”); (3) used entered value to calculate the assessment rate under 19 C.F.R. § 351.212(b) (1998); and (4) treated Koyo’s imported forged rings as in-scope merchandise subject to the TRB antidumping duty order. Timken contends that Commerce unlawfully: (1) applied adverse facts available to Koyo’s entered value; (2) failed to adjust CEP for indirect selling expenses reported by NTN, NSK and Koyo; (3) permitted NTN to exclude certain warehousing expenses attributable to non-scope merchandise from its reported United States indirect selling expenses; (4) accepted Koyo’s home market support rebates; (5) accepted Koyo’s home market “billing adjustment two”; (6) accepted NSK’s home market lump-sum rebates; and (7)accepted Koyo’s home market average short-term interest rate. BACKGROUND This case concerns the 1976 and 1987 antidumping duty orders on TRBs from Japan for the period of review (“POR”) covering October 1, 1995, through September 30,1996. On September 9, 1997, Commerce published the preliminary results of administrative reviews of the 1976 and 1987 antidumping duty orders. See Preliminary Results of Antidumping Duty Administrative Reviews of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From Japan, and Tapered Roller Bearings, Four Inches or Less in Outside Diameter, and Components Thereof, From Japan, (“Preliminary Results ”) 62 Fed.Reg. 47,452. Commerce published the Final Results on January 15, 1998, see 63 Fed.Reg. at 2558, and the Amended Final Results on March 19, 1998, see 63 Fed.Reg. 13,391. JURISDICTION The Court has jurisdiction over this matter pursuant to 19 U.S.C. § 1516a(a) (1994) and 28 U.S.C. § 1581(c) (1994). STANDARD OF REVIEW The Court will uphold Commerce’s final determination in an antidumping administrative review unless it is “unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(1)(B)(i) (1994); see NTN Bearing Corp. of Am. v. United States (“NTN Bearing”), 24 CIT -, - 104 F.Supp.2d 110, 115-16 (2000) (detailing Court’s standard of review for antidumping proceedings). DISCUSSION 1. Commerce’s Duty Absorption Inquiry A. Background Title 19, United States Code, § 1675(a)(4) provides that during an administrative review initiated two or four years after the publication of an antidump-ing duty order, Commerce, if requested by a domestic interested party, “shall determine whether antidumping duties have been absorbed by a foreign producer or exporter subject to the order if the subject merchandise is sold in the United States through an importer who is affiliated with such foreign producer or exporter.” Section 1675(a)(4) further provides that Commerce shall notify the International Trade Commission (“ITC”) of its findings regarding such duty absorption for the ITC to consider in conducting a five-year (“sunset”) review under 19 U.S.C. § 1675(c) (1994), and the ITC will take such findings into account in determining whether material injury is likely to continue or recur if an order were revoked under § 1675(c). See 19 U.S.C. § 1675a(a)(l)(D) (1994). On December 11, 1996, Timken requested Commerce to conduct a duty absorption inquiry pursuant to § 1675(a)(4) with respect to various respondents, including NTN, NSK and Koyo, to ascertain whether antidumping duties had been absorbed during the administrative reviews of the 1976 and 1987 antidumping duty orders. See Final Results, 63 Fed.Reg. at 2558. In the Final Results, Commerce found that duty absorption had occurred for the POR. See id. at 2559. In asserting authority to conduct a duty absorption inquiry under § 1675(a)(4), Commerce first explained that for “transition orders,” as defined in 19 U.S.C. § 1675(c)(6)(C) (anti-dumping duty orders, inter alia, orders issued on or after January 1, 1995), regulation 19 C.F.R. § 351.213Q) (1998) provides that Commerce “will make a duty-absorption determination, if requested, for any administrative review initiated in 1996 or 1998.” Final Results, 63 Fed.Reg. at 2558. Commerce concluded that: (1) because the antidumping duty orders on TRBs in this case have been in effect since 1976 and 1987, respectively, the orders are transition orders pursuant to § 1675(c)(6)(C); and (2) since these reviews were initiated in 1996 and a request was made, Commerce had the authority to make duty absorption inquiries for the administrative reviews of the 1976 and 1987 antidumping duty orders. See id. at 2558-59. B. Contentions of the Parties NTN, NSK and Koyo contend that Commerce lacked authority under § 1675(a)(4) to conduct a duty absorption inquiry for the POR of the outstanding 1976 and 1987 antidumping duty orders. See NTN’s Mem. Supp. Mot. J. Agency R. (“NTN’s Mem.”) at 27-32; NTN’s Reply Br. Jan. 22, 1999 Resp. Brs. United States and Timken (“NTN’s Reply”) at 2; NSK’s Mem. P. & A. Supp. Mot. J. Agency R. (“NSK’s Mem.”) at 12-16; NSK’s Reply Mem. Supp. Mot. J. Agency R. (“NSK’s Reply”) at 6-8; Koyo’s Mem. P. & A. Supp. Mot. J. Agency R. (“Koyo’s Mem.”) at 9-14; Koyo’s Reply Br. Supp. Mot. J. Agency R. (“Koyo’s Reply”) at 2-18. In the alternative, the parties assert that even if Commerce possessed the authority to conduct such an inquiry, Commerce’s methodology for determining duty absorption was contrary to law and, accordingly, the case should be remanded to Commerce to annul its duty absorption findings and conclusions. See NTN’s Mem. at 32-36; NSK’s Mem. at 12-16; Koyo’s Mem. at 15-16; Koyo’s Reply at 16-18. Commerce argues that it: (1) properly construed § 1675 subsections (a)(4) and (c) as authorizing it to make a duty absorption inquiry for antidumping duty orders that were issued and published prior to January 1, 1995; and (2) devised and applied a reasonable methodology for determining duty absorption. See Def.’s Mem. Opp’n Pis.’ Mots. J. Agency R. (“Def.’s Mem.”) at 13-31. Timken supports Commerce’s contentions. See Timken’s Resp. Pis.’ Mots. J. Agency R. (“Timken’s Resp.”) at 34-47. C. Analysis In SKF USA Inc. v. United States (“SKF USA Inc.”), 24 CIT -, 94 F.Supp.2d 1351 (2000), this Court determined that Commerce lacked statutory authority under § 1675(a)(4) to conduct a duty absorption inquiry for antidumping duty orders issued prior to the January 1, 1995 effective date of the URAA. See id. 24 CIT at -, 94 F.Supp.2d at 1357-59. The Court noted that Congress expressly prescribed in the URAA that § 1675(a)(4) “must be applied prospectively on or after January 1, 1995 for 19 U.S.C. § 1675 reviews.” Id. 24 CIT at -, 94 F.Supp.2d at 1359 (citing § 291 of the URAA). Because Commerce’s duty absorption inquiry, its methodology and the parties’ arguments are practically identical to those presented in SKF USA Inc., the Court adheres to its reasoning in SKF USA Inc. The statutory scheme clearly provides that the inquiry must occur in the second or fourth administrative review after the publication of the antidumping duty order, not in any other review, and upon the request of a domestic interested party. Accordingly, the Court finds that Commerce did not have statutory authority to undertake a duty absorption investigation for the anti-dumping duty orders in dispute here. The Court remands this case to Commerce with instructions to annul all findings and conclusions made pursuant to the duty absorption inquiry conducted for the subject review in accordance with this opinion. II. Denial of Price-Based LOT Adjustment for CEP Sales NTN contends that Commerce improperly denied a price-based LOT adjustment for CEP sales made in the United States market at an LOT different from the home market sales. See NTN’s Mem. at 37-39; NTN’s Reply at 3. In particular, NTN argues, inter alia, that Commerce incorrectly determined NTN’s CEP LOT because Commerce failed to use the sale to the first unaffiliated purchaser in the United States to determine NTN’s CEP LOT. See NTN’s Mem. at 38; NTN’s Reply at 4. NTN requests that the Court remand the LOT issue to Commerce to grant NTN a price-based LOT adjustment for its CEP sales. See NTN’s Mem. at 39; NTN’s Reply at 4. Commerce, in turn, argues that it properly determined the LOT for NTN’s CEP sales based upon the CEP. See Def.’s Mem. at 37. Commerce deducted expenses and profit from the price to the first unaffiliated purchaser in the United States pursuant to § 1677a(d) since § 1677b(a)(7)(A) (1994) provides for an LOT adjustment and requires Commerce to compare normal value (“NV”) to CEP rather than to the unadjusted starting price of CEP. See id. (citing Final Results, 63 Fed.Reg. at 2577). Commerce points out that CEP is defined in § 1677a(b) (1994) as the price to the “unaffiliated purchaser in the United States as adjusted” under § 1677a(d). Def.’s Mem. at 40. According to Commerce, the adjusted CEP price is to be compared to prices in the home market based on the same LOT whenever it is practicable; when it is not practicable and the LOT difference affects price comparability, Commerce makes an LOT adjustment. See id. at 34, 36. Commerce makes a CEP offset when Commerce is not able to quantify price differences between the CEP LOT and the LOT of the comparison sales, and if NV is established at a more advanced state of distribution than the CEP LOT. See id. at 36. Therefore, Commerce claims that it properly denied an LOT adjustment for NTN’s CEP sales because NTN did not have a home-market LOT equivalent to the CEP LOT, making it impossible for Commerce to quantify the difference in price between the CEP LOT and the home market LOT. See id. Because the home market LOT was at a more advanced stage of distribution than the CEP LOT, Commerce made a CEP offset pursuant to 19 U.S.C. § 1677b(a)(7)(B). See id. Timken generally agrees with Commerce’s positions. See Timken’s Resp. at 67-69. In Micron Tech., Inc. v. United States (“Micron”), 243 F.3d 1301 (Fed.Cir.2001), the Court of Appeals for the Federal Circuit (“CAFC”) held that the plain text of the antidumping statute and the Statement of Administrative Action (“SAA”) require Commerce to deduct the expenses enumerated under § 1677a(d) before making the LOT comparison. The court examined § 1677b(a)(l)(B)(i) (1994), which provides that Commerce must establish NV “to the extent practicable, at the same level of trade as the export price or [CEP],” and § 1677a(b), which defines CEP as “the price at which the subject merchandise is first sold (or agreed to be sold) in the United States ... as adjusted under sub sections (c) and (d) of this section.” (Emphasis supplied). The court concluded that, “[as][r]ead together, these two provisions show that Commerce is required to deduct the subsection (d) expenses from the starting price in the United States before making the level of trade comparison.” Micron, 243 F.3d at 1315. The court further stated that this conclusion is mandated by the SAA, which states that “ ‘to the extent practicable, [Commerce should] establish normal value based on home market (or third country) sales at the same level of trade as the constructed export price or the starting price for the export price.’” Id. (citing SAA at 829). Thus, the Court finds that Commerce properly made § 1677a(d) adjustments to NTN’s starting price in order to arrive at CEP and make its LOT determination. The Court also finds that Commerce’s decision to deny NTN an LOT adjustment is supported by substantial evidence. Section 1677b(a)(7)(A) permits Commerce to make an LOT adjustment “if the difference in level of trade ... involves the performance of different selling activities! ] and ... is demonstrated to affect price comparability, based on a pattern of consistent price differences between sales at different levels of trade in the country in which normal value is determined.” With respect to CEP sales, Commerce found that the same LOT as that of the CEP for merchandise under review did not exist for any respondent in the home market; therefore, Commerce was unable to “determine whether there was a pattern of consistent price differences between the LOTs based upon the respondent’s home market sales of merchandise under review.” See Def.’s Mem. at 36. Commerce recognized that the SAA provides alternative methods for calculating LOT adjustments, but it determined “that it would have been inappropriate to apply a LOT adjustment to any respondent.” See id. Consequently, with respect to the CEP sales where Commerce was unable to quantify an LOT adjustment, Commerce, in accordance with § 1677b(a)(7)(B) granted a CEP offset to respondents, including NTN, because the home market sales were at a more advanced LOT than the sales to the United States. See id. The Court finds that Commerce acted within the directive of the statute in denying the LOT adjustment and granting a CEP offset instead. See 19 U.S.C. § 1677b(a)(7). III. Commerce’s Reallocation of NTN’s Home Market and United States Selling Expenses Without Regard to LOT A. Background In its preliminary calculations, Commerce calculated NTN’s United States and home market selling expenses without regard to LOT. See Final Results, 63 Fed. Reg. at 2579. NTN argued that Commerce should have relied on NTN’s reported United States and home market selling expenses based on LOT instead of recalculating these selling expenses without regard to LOT. See id. Timken, in turn, contended that Commerce should reject NTN’s selling expense allocations based on LOT because such allocations bear no relationship to the way in which NTN incurs the expenses. See id. Commerce responded that for a majority of the expenses under this POR, it determined that NTN’s methodology for allocating its selling expenses based on LOTs did not bear any relationship to the manner in which NTN incurred these United States and homemarket selling expenses and its methodology led to distorted allocations. See id. Commerce asserts that in Timken Co. v. United States (“Timken I”), 20 CIT 645, 930 F.Supp. 621 (1996), Commerce was to accept “NTN’s LOT-specific allocations and per-unit LOT expense adjustment amounts only if NTN’s expenses demonstrably varied according to LOT.” Id. (citing Timken I, 20 CIT at 653, 930 F.Supp. at 629). Acting in accordance with Timken I, Commerce in its remand results did not allow NTN’s LOT-specific allocations “due to the lack of quantitative and narrative evidence on the record demonstrating that the expenses in question demonstrably varied according to LOT.” Final Results, 63 Fed.Reg. at 2579. Since Commerce found during this POR that except for certain United States and home market packing material and packing labor expenses NTN did not provide “quantitative and narrative evidence” that its selling expenses are attributable to levels of trade, Commerce recalculated NTN’s United States and home market selling expenses without regard to LOT. See id. at 2579-80. B. Contentions of the Parties NTN contends that Commerce’s decision to reallocate NTN’s selling expenses violates Commerce’s mandate to administer the antidumping laws. See NTN’s Mem. at 40. NTN notes that Commerce: (1) has accepted NTN’s methodology of allocating its selling expenses based on LOT in previous reviews; and (2) even stated that NTN’s “detailed and often complex U.S. expense reporting methodologies result in reasonable allocations.” Id. at 40-41 (quoting Final Results of Anti-dumping Duty Administrative Reviews and Revocation in Part of an Antidump-ing Finding on Tapered Roller Bearings and Parts Thereof Finished and XJnfin-ished, From Japan and Tapered Roller Bearings, Four Inches or Less in Outside Diameter, and Components Thereof, From Japan, 61 Fed.Reg. 57,629, 57,636 (Nov. 7, 1996)). Moreover, NTN argues that Commerce’s rejection of NTN’s reporting methodology on the basis of complexity is not a reasonable rationale for reallocating NTN’s selling expenses. NTN’s Mem. at 39, 40. NTN contends that such reallocation has the effect of voiding Commerce’s LOT determination that different LOTs exist in the United States and Japan. See id. at 41. Commerce responds that there is no evidence of narrative or quantitative analysis tying the allocation method to the expenses. See Def.’s Mem. at 45. Commerce asserts that NTN only quantified the allocation itself and, therefore, the Court should sustain the agency’s recalculation of NTN’s United States and home market selling expenses. See id. at 46. Timken supports Commerce and argues that Commerce was correct in rejecting NTN’s allocation of United States and homemarket selling expenses on an LOT- ■ specific basis because “the record did not contain ‘quantitative and narrative evidence demonstrating’ that sales at different levels incurred different amounts of the expenses.” See Timken’s Resp. at 69 (quoting Final Results, 63 Fed.Reg. at 2580). C. Analysis The Court disagrees with NTN that it adequately supported its LOT adjustment claim for its reported United States and home-market selling expenses. Although NTN purports to show that it incurred different selling expenses at different trade levels, the evidence to which it points does not show that its allocation methodology reasonably quantifies the United States and home-market selling expenses incurred at different LOTs. See NTN Bearing, 24 CIT at -, 104 F.Supp.2d at 131-33; NTN, 19 CIT at 1234, 905 F.Supp. at 1095. Given that NTN had the burden before Commerce to establish its entitlement to an LOT adjustment, its failure to provide the requisite evidence compels the Court to conclude that it has not met its burden of demonstrating that Commerce’s denial of the LOT adjustment was not supported by substantial evidence and was not in accordance with law. See NSK Ltd. v. United States (“NSK Ltd.”), 21 CIT 617, 635-36, 969 F.Supp. 34, 55 (1997), aff'd, NSK Ltd. v. Koyo Seiko Co., Ltd. (“NSK”), 190 F.3d 1321, 1330 (Fed.Cir.1999). Accordingly, the Court sustains Commerce’s recalculation of NTN’s United States and home market selling expenses without regard to levels of trade. IV. NTN’s Constructed Export Price Calculation A. NTN’s Constructed Export Price Calculation Without Regard to LOT 1. Background In calculating CEP, Commerce must reduce the starting price used to establish CEP by “the profit allocated to the expenses described in paragraphs (1) and (2)” of § 1677a(d). 19 U.S.C. § 1677a(d)(3). Under 19 U.S.C. § 1677a(f) (1994), the “profit” that is deducted from this starting price is “determined by multiplying the total actual profit by [a] percentage” calculated “by dividing the total United States expenses by the total expenses.” 19 U.S.C. § 1677a(f)(l) and (2)(A). Section 1677a(f)(2)(B) defines “total United States expenses” as the total expenses deducted under § 1677a(d)(l) and (2), that is, commissions, direct and indirect selling expenses, assumptions, and the cost of any further manufacture or assembly in the United States. Section 1677a(f)(2)(C) establishes a tripartite hierarchy of methods for calculating “total expenses.” First, “total expenses” could be the “expenses incurred with respect to the subject merchandise sold in the United States and the foreign like product sold in the exporting country” if Commerce requested such expenses for the purpose of determining NV and CEP. Id. § 1677a(f)(2)(C)(i). If Commerce did not request these expenses, then “total expenses” are the “expenses incurred with respect to the narrowest category of merchandise sold in the United States and the exporting country which includes the subject merchandise.” 19 U.S.C. § 1677a(f)(2)(C)(ii). If the data necessary to determine “total expenses” under either of these methods is not available, then “total expenses” are the “expenses incurred with respect to the narrowest category of merchandise sold in all countries which includes the subject merchandise.” 19 U.S.C. § 1677a(f)(2)(C)(iii). “Total actual profit” is based on whichever category of merchandise is used to calculate “total expenses” under § 1677a(f)(2)(C). See 19 U.S.C. § 1677a(f)(2)(D). During this POR, NTN argued that profit levels differed by LOT and had an effect on prices and CEP profit and, therefore, Commerce should calculate CEP profit on an LOT-specific basis rather than for each class or kind of merchandise. See Final Results, 63 Fed.Reg. at 2570. NTN reasoned that § 1677a(f)(2)(C) “expresses a preference for the [CEP] profit calculations to be performed as specifically as possible and on the narrowest basis as possible.” Id. Commerce rejected NTN’s argument, concluding that: (1) “[njeither the statute nor the SAA require[s] [Commerce] to calculate CEP profit on a basis more specific than the subject merchandise as a whole”; (2) basing the CEP-profit calculation on an LOT-specific basis would “add a layer of complexity to an already complicated exercise with no increase in accuracy”; and (3) a subdivision “of the CEP-profit calculation would be more susceptible to manipulation.” Id. (Commerce also relied on its detailed explanation made in the sixth review of the antifriction bearings (“AFBs”)). 2. Contention of the Parties NTN contends that Commerce erred by refusing to calculate CEP profit on an LOT-specific basis. See NTN’s Mem. at 16. Highlighting the “narrowest category of merchandise” language of § 1677a(f)(2)(C)(ii) and (iii), NTN argues that there is a clear statutory preference that profit be calculated on the narrowest possible basis. See id. at 17. Moreover, NTN claims that since CV profit is calculated by LOT and matching is by LOT, CEP profit should be calculated to account for differences in LOT. See id. NTN asserts that the mere fact that a calculation is difficult is not a valid reason to sacrifice accuracy. See id. NTN further asserts that Commerce’s speculation that an adjustment is susceptible to manipulation provides no grounds for rejecting an adjustment. See id. at 16. Commerce responds that it properly determined CEP profit without regard to LOT. See Def.’s Mem. at 50. Commerce notes that § 1677a(f) does not refer to LOT, that is, the statute does not require that CEP profit be calculated on an LOT-specific basis. See id. at 51. In addition, Commerce asserts that even assuming that a narrower basis for the CEP-profit calculation is warranted in some circumstances, NTN has not provided any factual support for such a deviation from Commerce’s standard methodology for calculating CEP profit. See id. at 52. Timken generally agrees with Commerce’s CEP-profit calculation. See Timken’s Resp. at 59-60. 3. Analysis Section 1677a(f), as Commerce correctly notes, does not make any reference to LOT. Accordingly, the Court’s duty under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (“Chevron ”), 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984), is to review the reasonableness of Commerce’s statutory interpretation. See IPSCO, Inc. v. United States (“IPSCO ”), 965 F.2d 1056, 1061 (Fed.Cir.1992) (citing Chevron, 467 U.S. at 844, 104 S.Ct. 2778). Commerce’s refusal to calculate CEP profit on an LOT-specific basis is reasonable and in accordance with law. See NTN Bearing, 24 CIT at -, 104 F.Supp.2d at 133-35. The language of the statute clearly contemplates that, in general, the “narrowest category” will include the class or kind of merchandise that is within the scope of an investigation or review. See id. Subsections (ii) and (iii) of § 1677a(f)(C)’s “total expense” definition lead to such conclusion because both subsections refer to “expenses incurred with respect to the narrowest category of merchandise ... which includes the subject merchandise.” See id. at 135. The term “subject merchandise” is defined as “the class or kind of merchandise that is within the scope of an investigation, a review, a suspension agreement, an order under this subtitle or section 1303 of this title, or a finding under the Antidumping Act, 1921.” 19 U.S.C. § 1677(25) (1994). Accordingly, the Court finds that Commerce reasonably interpreted § 1677a(f) in refusing to apply a narrower subcategory of merchandise such as one based on LOT. The Court, moreover, agrees with Commerce’s conclusion that a subdivision of the “CEP-profit calculation would be more susceptible to manipulation,” a result that Congress specifically warned Commerce to prevent. Final Results, 63 Fed.Reg. at 2570. Finally, the Court agrees with Commerce that NTN failed to provide adequate factual support of how the CEP-profit calculation was distorted by Commerce’s standard methodology. B. Inclusion of EP Sales in Calculation of NTN’s Constructed Export Price Profit 1. Background Under 19 U.S.C. § 1677a(d)(3), Commerce must, in order to calculate CEP, deduct “the profit allocated to the expenses described in” 19 U.S.C. § 1677a(d)(l) and (2) from the price charged to the first unaffiliated purchaser in the United States. “Profit” is defined as “an amount determined by multiplying the total actual profit by the applicable percentage,” 19 U.S.C. § 1677a(f)(l), and “actual profit” is defined as the “total profit earned ... with respect to the sale of the same merchandise for which total expenses are determined .... ” 19 U.S.C. § 1677a(f)(2)(D). The term “total expenses” means “all expenses in the first of [three] categories which applies and which are incurred by or on behalf of the foreign producer and foreign exporter of the subject merchandise and by or on behalf of the United States seller affiliated with the producer or exporter with respect to the production and sale of such merchandise ....” 19 U.S.C. § 1677a(f)(2)(C). The first category covers “expenses incurred with respect to the subject merchandise sold in the United States and the foreign like product sold in the exporting country ....” 19 U.S.C. 1677a(f)(2)(C)(i). “Subject merchandise,” in turn, is defined as “the class or kind of merchandise that is within the scope of ... a review ....” 19 U.S.C. § 1677(25). In the Final Results, Commerce included EP sales in the calculation of CEP profit. See generally, 63 Fed.Reg. at 2570. 2. Contentions of the Parties NTN contends that the statute clearly states that the adjustment of profit to the CEP is to be based on expenses incurred in the United States as a percentage of total expenses and that there is no provision in the statute for the inclusion of EP expenses or profit in this calculation. See NTN’s Mem. at 17-19. NTN deduces, therefore, that Commerce erred by including EP sales in the calculation of CEP profit. Id. at 19. Specifically, NTN relies on the definition of the term “total expenses.” See 19 U.S.C. § 1677a(f)(2)(C). NTN maintains that the specific reference to CEP within the definition precludes Commerce from the inclusion of EP expenses in the calculation of CEP profit. See NTN’s Mem. at 17-18. NTN further states that “just as EP expenses cannot be considered, it follows logically that sales revenue for EP sales also cannot be included [in the calculation of CEP profit]” since the definition of “total actual profit,” 19 U.S.C. § 1677a(f)(2)(D), “directly references the definition of ‘total expenses.’ ” Id at 19. NTN, therefore, requests that EP sales be removed from NTN’s CEP profit adjustment calculation. See id Commerce contends that the inclusion of revenues and expenses resulting from NTN’s EP sales in the calculation of CEP profit was in accordance with the law because it was a reasonable interpretation of the statutory mandates of sections 1677a(f)(2)(C) and (D) and 1677(25) of Title 19. See Def.’s Mem. at 49. Specifically, Commerce points out that the term “subject merchandise” is defined as “ ‘the class or kind of merchandise that is within the scope of ... a review ....’” Id (quoting 19 U.S.C. § 1677(25)). Commerce notes that the term “subject merchandise” is referred to in the statute that defines “total expenses,” see 19 U.S.C. § 1677a(f)(2)(C)(i), and therefore, “total expenses” encompasses NTN’s EP and CEP sales. See Def.’s Mem. at 49. Commerce further articulates that: [t]he basis for total actual profit is the same as the basis for total expenses ... [see 19 U.S.C. § 1677a(f)(2)(C)(1994) ]. The first alternative under [19 U.S.C. § 1677a(f)(2)(C) ] states that, for purposes of determining profit, the term “total expenses” refers to all expenses incurred with respect to the subject merchandise sold in the United States (as well as home market expenses). Thus, where the respondent makes both EP and CEP sales to the United States, sales of the subject merchandise would encompass all such transactions. Therefore, because NTN had EP sales, [Commerce] ... included these sales in the calculation of CEP profit. Final Results, 63 Fed.Reg. at 2570. Commerce also points out that its September 4, 1997 policy bulletin explains that 19 U.S.C. § 1677a(f)(2)(D) “provides that the calculation of ‘total actual profit’ is to include all revenues and expenses resulting from the respondent’s EP sales as well as from its CEP and home market sales.” Def.’s Mem. at 49 (citing Commerce’s Policy Bulletin 97.1 of September 4, 1997). Timken agrees with Commerce and contends that Commerce reasonably calculated CEP profit -on the basis of all United States sales, including EP sales. See Timken’s Resp. at 60-61. In addition, Timken argues that the Court lacks jurisdiction over the issue of the inclusion of EP' sales in the calculation of NTN’s CEP profit because Commerce did not ultimately make a CEP profit adjustment. See Timken’s Resp. at 59 (proprietary version). 3. Analysis Based upon the above-defined statutory scheme, Commerce concluded that where a respondent made both EP and CEP sales, “sales of the subject merchandise” encompassed all such transactions and, therefore, Commerce could reasonably interpret the statutory scheme as providing that the calculation of total actual profit is to include all revenues and expenses resulting from the respondent’s EP sales as well as from its CEP and home-market sales. See Def.’s Mem. at 49. Commerce’s September 4, 1997 policy bulletin provides: The calculation of total actual profit under [19 U.S.C. § 1677a(f)(2)(D) ] includes all revenues and expenses resulting from the respondent’s [EP] sales as well as from its constructed export price and home market sales .... The basis for total actual profit is the same as the basis for total expenses under [19 U.S.C. § 1677a(f)(2)(C) ]. The first alternative under this section ... states that, for purposes of determining profit, the term “total expenses” refers to all expenses incurred with respect to the subject merchandise sold in the United States (as well as home market expenses). Thus, where the respondent makes both EP and CEP [sales], sales of the subject merchandise would encompass all such transactions. Def.’s Mem. at 49. The SAA further clarifies the point and states the following: The total expenses are all expenses incurred by or on behalf of the foreign producer and exporter and the affiliated seller in the United States with respect, to the production and sale of the first of the following alternatives which applies: (1) the subject merchandise sold in the United States and the foreign like product sold in the exporting country (if Commerce requested this information in order to determine the normal value and the constructed export price) .... H.R. Doc. 103-316 at 824. Based upon its interpretation of the statutory language and upon the SAA’s reference to CEP, NTN claims that there are only two categories of expenses that Commerce could use in calculating CEP profit: those used to calculate NV and those used to calculate CEP. See NTN’s Mem. at 18. Additionally, NTN states that just as EP expenses cannot be used in calculating CEP profit, neither can sales revenue be used for EP sales since the definition of “total actual profit” under 19 U.S.C. § 1677a(f)(2)(D) refers to the definition of “total expenses” in 19 U.S.C. § 1677a(f)(2)(C). See id. NTN, however, ignores two issues. To start, the first category of total expenses under § 1677a(f)(2)(C) is not limited to expenses incurred with respect to CEP sales made in the United States and the foreign like product sold in the exporting country. It also covers expenses incurred with respect to EP sales because it refers to “expenses incurred with respect to the subject merchandise sold in the United States”; the term “subject merchandise” is defined in 19 U.S.C. § 1677(25) as the class or kind of merchandise that is within the scope of a review; and the class or kind of merchandise in this review includes both CEP and EP sales. Second, as the SAA explains, the total expenses are all expenses incurred with respect to the production and sale of the first of the three alternatives. In referring to the first category of expenses, the SAA specifically refers to “the subject merchandise sold in the United States,” which by definition means the class or kind of merchandise which is within the scope of a review and, in this review, includes both CEP and EP sales. H.R. Doc. 103— 316 at 824. For these reasons the Court is not convinced by NTN’s argument that Commerce’s interpretation of the statutory scheme is unreasonable and sustains Commerce’s inclusion of EP sales in the calculation of CEP profit. See Chevron, 467 U.S. 837, 104 S.Ct. 2778. V. Commerce’s Recalculation of Credit Expenses for Constructed Export Price Sales A. Background During the POR, NTN calculated its United States credit expense for CEP sales on a customer-specific basis. See NTN’s Mem. at 23-24 and Ex. “U.S. Verification Report.” “NTN calculated the average days of payment for each customer, and multiplied the average number of days by the interest rate to arrive at a credit expense.” Def.’s Mem. at 53. During the review, Timken contended that Commerce “should recalculate NTN’s U.S. credit expense because NTN reported a customer-specific average credit expense rather than a transaction-specific credit expense” thereby producing distortive results. Final Results, 63 Fed.Reg. at 2571. Timken noted that NTN “provided the necessary information on record to recalculate a credit expense on a transaction-specific” basis. Id. NTN responded that its credit expense should not be recalculated because Commerce had accepted NTN’s methodology of reporting a customer-specific credit expense in previous AFB reviews and “verified the accuracy of NTN’s data” for this and other reviews. See id. at 2572; see also NTN’s Mem. at 23 (citing 1997 Final Results, 62 Fed.Reg. 54,043, 54,066-54,067 [sic]. Commerce agreed with Timken with regards to CEP sales, finding: We have data on the record which allows us to calculate a transaction-specific credit expense for CEP sales. Therefore, we have recalculated NTN’s credit expense using the dates of payment which NTN reported. Final Results, 63 Fed.Reg. at 2572. B. Contentions of the Parties NTN notes that Commerce has accepted NTN’s calculation of credit expenses on a customer-specific basis for previous anti-dumping duty orders on AFBs from Japan. See NTN’s Mem. at 23. NTN contends that since “NTN has not modified its reporting methodology, and [Commerce] verified NTN’s reported expenses, it is inappropriate and contrary to law for [Commerce] to modify NTN’s reported data.” Id. Moreover, NTN asserts that Commerce’s recalculation of NTN’s credit expense on a transaction-specific basis, rather than the use of NTN’s reported customer-specific credit expense, constitutes unlawful use of facts available under 19 U.S.C. § 1677e (1994). See id. at 23-25. Commerce asserts that its “question-name instructed [NTN] as to the proper method for calculating and reporting credit expenses.” Def.’s Mem. at 52 and Ex. 3. In particular, Commerce’s preference for the reporting of credit expenses is that they be reported on a transaction-specific basis rather than on an average or allocated basis. See Def.’s Mem. at 52-53. However, Commerce claims that when a company’s records do not permit transaction-specific reporting, Commerce has permitted use of average or allocated expenses, that is, customer-specific reporting. See id. at 53. Commerce argues that since NTN provided the necessary information on record which permitted a transaction-specific calculation of NTN’s United States credit expenses for CEP sales, Commerce properly exercised its preference and recalculated the expenses on such a basis. See id. at 53-54. Additionally, Commerce contends that NTN’s argument declaring Commerce’s recalculation of credit expense on a transaction-specific basis as “impermissible use of facts available” under 19 U.S.C. § 1677e has no merit since Commerce did not resort to any data other than that reported by NTN. See id. at 54. Timken agrees with Commerce, noting that, consistent with the antidumping statute, Commerce has a preference for transaction-specific reporting of credit expenses since actual costs allow Commerce to determine “the most accurate dumping margins possible.” Timken’s Resp. at 65. Timken notes that Commerce’s questionnaire requesting information indicated a strong preference for reporting credit expenses on a transaction-specific basis. See id. Since the record contained information reported by NTN that permitted more precise credit expense calculations, that is, transaction-specific payment dates for NTN’s CEP sales, Timken contends that Commerce properly recalculated NTN’s United States credit expenses on a transaction-specific basis. See id. Also, Timken asserts that Commerce’s use of NTN’s reported verified sale and payment dates to recalculate NTN’s credit expense on a transaction-specific basis does not constitute the unlawful “use of facts available.” See id. C. Analysis The Court disagrees with NTN that Commerce is now prohibited from using transaction-specific reporting of NTN’s United States credit expense merely because Commerce had accepted NTN’s customer-specific reporting of such expenses in previous AFB reviews and verified the accuracy of NTN’s data for this and other reviews. Commerce does not have to adhere to its customer-specific reporting methodology for calculating credit expenses when a respondent provides the necessary information on record for calculating such expenses on a more accurate and preferred basis, that is, a transaction-specific basis. See generally NSK Ltd. v. United States (“NSK 1995 ”), 19 CIT 1013, 1027, 896 F.Supp. 1263, 1275 (1995), rev’d on other grounds, 115 F.3d 965 (Fed.Cir.1997), (noting that Commerce does not have to “adhere to its prior reporting methodology, especially where Commerce is striving for more accuracy” and explaining that “[d]irect selling expenses are incurred with respect to specific transactions. Credit, for example, is a selling expense which is only incurred when credit is extended under the terms of sale. Because credit expense is a direct expense, it should be tied to the transaction for which it was incurred”). The Court also finds that NTN’s argument that Commerce’s recalculation of NTN’S United States credit expense on a transaction-specific basis constitutes the unlawful “use of facts available” under 19 U.S.C. § 1677e has no merit since NTN clearly misreads the clear language of that statute. The antidumping statute mandates that Commerce use “facts otherwise, available” (commonly referred to as “facts available”) if “necessary information is not available on the record” of an antidumping proceeding. 19 U.S.C. § 1677e(a)(l). In addition, Commerce may use facts available where an interested party or any other person: (1) withholds information that has been requested by Commerce; (2) fails to provide the requested information by the requested date or in the form and manner requested, subject to 19 U.S.C. § 1677m(c)(l), (e) (1994); (3) significantly impedes an antidumping proceeding; and (4) provides information that cannot be verified as provided in 19 U.S.C. § 1677m(i) (1994). See 19 U.S.C. § 1677e(a)(2)(A)-(D). Section 1677e(a) provides, however, that the use of facts available shall be subject to the limitations set forth in 19 U.S.C. § 1677m(d)(1994). The legislative goal behind Commerce’s right to use facts available is to “induce respondents to provide Commerce with requested information in a timely, complete, and accurate manner .... ” National Steel Corp. v. United States, 18 CIT 1126, 1129, 870 F.Supp. 1130, 1134 (1994). Consequently, Commerce enjoys very broad, although not unlimited, discretion with regard to the propriety of its use of facts available. See generally, Olympic Adhesives, Inc. v. United States, 899 F.2d 1565 (Fed.Cir.1990) (acknowledging Commerce’s broad discretion with regard to the use of facts available but pointing out that Commerce’s resort to facts available is an abuse of discretion where the information Commerce requests does not and could not exist). During the review at issue, NTN complied with Commerce’s request for data by providing the necessary information on record which permitted a transaction-specific calculation of NTN’s United States credit expenses for CEP sales. See Final Results at 2572. Since Commerce did not resort to any data other than that reported by NTN, Commerce’s recalculation of NTN’s United States credit expense on a transaction-specific basis did not constitute the unlawful use of “facts available” under 19 U.S.C. § 1677e. Accordingly, the Court finds that Commerce’s recalculation of NTN’s United States credit expense on a transaction-specific basis was supported by substantial evidence and in accordance with law. VI. Denial of an Adjustment to United States Indirect Selling Expenses for Interest Allegedly Incurred in Financing Cash Deposits for Anti-dumping Duties A. Background During the review, NTN claimed a downward adjustment to its reported United States indirect selling expenses for imputed interest expenses allegedly incurred in financing cash deposits for anti-dumping duties. See Final Results, 63 Fed.Reg. at 2570-71. Commerce denied the adjustment and determined that such an interest offset to NTN’s indirect selling expenses is inappropriate, whether based on actual interest expenses or an imputed amount allegedly associated with financing cash deposits. See id. at 2571. Commerce thereby deducted the entire amount of NTN’s reported indirect selling expenses, including all interest, from the CEP. See Def.’s Mem. at 55-56. Commerce noted that 19 U.S.C. § 1677a(d)(l), which provides for the deduction of certain selling expenses from CEP that were “incurred by or for the account of the producer or exporter, or the affiliated seller in the United States, in selling the subject merchandise,” does not precisely define what constitutes a selling expense; instead, Congress has given Commerce discretionary authority to determine what such an expense encompasses. See Final Results, 63 Fed.Reg. at 2571. Commerce acknowledged that in past reviews of the applicable antidumping duty orders, it determined that interest expenses incurred in financing antidump-ing duty cash deposits were not considered selling expenses and thereby allowed an offsetting, financing-cost adjustment to United States indirect selling expenses. See id. For this review, however, Commerce reconsidered its position and concluded that this offsetting financing-cost adjustment is inappropriate. See id. Commerce found that while under the statute it may allow a limited exemption from deductions from United States price for antidumping duty cash deposits and legal fees associated with participation in an antidumping case, it found no basis for extending this exemption to interest expenses allegedly incurred in financing the cash deposits. See id. The agency reasoned that there is a distinction “between business expenses that arise from economic activities in the United States and business expenses that are direct, inevitable consequences of an antidumping duty order.” Id. Commerce determined that while cash deposits and legal fees are incurred solely as a result of the existence of an antidumping order, “[financial expenses allegedly associated with cash deposits are not a direct, inevitable consequence of an antidumping duty order.” Id. In particular, Commerce explained that although it may be true that some importers sometimes incur a cost if they borrow money in order to pay for cash deposits of antidumping duties, it is a fundamental principle that: “[mjoney is fungible. If an importer acquires a loan to cover one operating cost, that may simply mean that it will not be necessary to borrow money to cover a different operating cost.” Companies may choose to meet obligations for cash deposits in a variety of ways that rely on existing capital resources or that require raising new resources through debt or equity. For example, companies may choose to pay deposits by using cash on hand, obtaining loans, increasing sales revenues, or raising-capital through the sale of equity shares. In fact, companies face these choices every day regarding all their expenses and financial obligations. There is nothing inevitable about a company having to finance cash deposits and there is no way for [Commerce] to trace the motivation or use of such funds even if it were. Id. (quoting Preliminary Results, 62 Fed. Reg. at 47,455). Commerce also noted that “the calculation of the dumping margins should not vary depending on whether a party has funds available to pay cash deposits or requires additional funds in the form of loans.” Preliminary Results, 62 Fed.Reg. at 47,455. Moreover, Commerce determined that it should not impute an amount for any interest costs that would theoretically be associated with financing actual cash deposits of antidumping duties. Final Results, 63 Fed.Reg. at 2571. Commerce reasoned that [t]here is no real opportunity cost associated with cash deposits when the paying of such deposits is a precondition for doing business in the United States.... Companies cannot choose not to pay-cash deposits if they want to import nor can they dictate the terms, conditions, or timing of such payments. Id. B. Contentions of the Parties NTN claims that Commerce’s rationale for denying NTN’s adjustment for interest expenses is flawed because irrespective of how a company opts to finance the cash deposits for antidumping duties, the amount of cash deposited will have to be made up by financing something else, a result that is a direct inevitable consequence of the antidumping duty order. See NTN’s Mem. at 20. NTN also asserts that if Commerce were to allow the interest expenses from cash deposits from prior reviews to affect the dumping margin calculations of present reviews, a never-ending cycle would follow that would prevent Commerce from ever revoking the anti-dumping duty order. See id. at 21. Further, NTN notes that Commerce has repeatedly taken the position that interest expenses incurred in financing cash deposits of antidumping duties cannot be properly treated as indirect selling expenses and, therefore, has allowed for an interest-expense adjustment on antidumping duty cash deposits. See id. at 20-22 (citations omitted). NTN asserts that Commerce’s decision to alter its prior methodology is “unreasonable and internally-contradictory.” NTN’s Reply at 7. NTN also asserts that this Court has consistently upheld the interest-expense adjustment to indirect selling expenses when Commerce has granted it and has remanded to Commerce to allow the adjustment when the agency has denied it. See NTN’s Mem. at 22-23 (citations omitted). In particular, NTN argues that Federal-Mogul Corp. v. United States (“Federal-Mogul”), 20 CIT 1438, 1440-41, 950 F.Supp. 1179, 1182-83 (1996), clearly refutes Commerce’s decision to deny NTN’s interest-expense adjustment. See id. at 22. In particular, NTN notes the court in Federal-Mogul found that there was no support for a domestic party’s “assertion that any expense related to antidumping proceedings is automatically a selling expense related to the sale of the subject merchandise. Indeed, pursuant to the rationale of [Daewoo Elees. Co. v. United States (“Daewoo ”), 13 CIT 253, 270, 712 F.Supp. 931, 947 (1989) ], such expenses are not necessarily selling expenses.” Id. at 22 (quoting Federal-Mogul, 20 CIT at 1440-41, 950 F.Supp. at 1183). NTN points out that the court in Federal-Mogul found that, similar to the Daewoo court’s holding that legal expenses related to anti-dumping proceedings are not selling expenses, the interest expenses at issue did not qualify as selling expenses because they were not related to the sale of merchandise, but to NTN’s participation in the antidumping proceeding. See id. NTN also notes that in NSK Ltd., 21 CIT at 637, 969 F.Supp. at 55, the Court reaffirmed its decision in Federal-Mogul to allow NTN’s adjustment for interest expenses on anti-dumping duty cash deposits. See id. at 23. NTN contends that Commerce’s decision to alter its policy is unreasonable and there is no danger that an interest-expense adjustment to indirect selling expenses would be used to “mask dumping.” See id.; NTN’s Reply at 7. Commerce argues that its decision to deny the offset was within its discretion. See Def.’s Mem. at 57. Commerce also argues that it may change its methodology if it presents a reasonable basis for departing from its previous practice. See id. at 57-59. Further, Commerce contends that the interest expenses allegedly incurred with financing antidumping duty cash deposits are ordinary interest expenses and, therefore, not deductible from United States indirect selling expenses. See id. at 59. Timken asserts that Commerce reasonably denied the offset, because allowing United States selling expenses to be reduced in the manner claimed by NTN encourages dumping. See Timken’s Resp. at 63. Specifically, Timken argues that an adjustment for NTN’s interest expenses on antidumping duty cash deposits would “allow NTN to mask present dumping through alleged interest used to finance past cash deposits.” Id. Timken contends for example that: the interest might be equal to five percent of the value of U.S. sales in the present review. Under NTN’s approach, the Commerce Department would be required to offset expenses attributable to sales made during the present administrative review with interest imputed to past cash deposits. Thus, the importer may sell at prices five percent less than fair value without being found to have dumped. The Commerce Department would offset reductions amounting to five percent of U.S. sales prices with the five percent imputed interest. The offset would mask the importer’s dumping, and the importer would escape the coverage of the anti-dumping duty law. Id. Timken also argues that other than NTN’s reported “amount of imputed interest attributable to its cash antidumping duty deposits,” there is no evidence that NTN actually obtained loans for the purpose of posting cash deposits. Id. at 64. Therefore, there is no factual basis for the adjustment. See id. C. Analysis Although NTN correctly points out that interest expenses incurred on financing antidumping cash deposits are not “selling expenses,” see Federal-Mogul, 20 CIT at 1441, 950 F.Supp. at 1183, the Court disagrees that Commerce in this review is prevented from altering its methodology of making adjustments to United States indirect selling expenses. This Court has noted that “Commerce may, in certain circumstances, reasonably change its methodology from review to review.” Timken Co. v. United States (“Timken ”), 21 CIT 1313, 1332, 989 F.Supp. 234, 250 (1997), vacated in part on other grounds, 1 F.Supp.2d 1390, 1393 (1998) (allowing Commerce to alter its methodology with respect to interest expenses incurred for financing cash deposits). Consequently, since 19 U.S.C. § 1677a(d) does not provide clear guidance with respect to the adjustment, the issue for the Court is whether Commerce’s interpretation of the statute was reasonable. The Court finds that Commerce reasonably interpreted the statute by concluding that financing expenses incurred on anti-dumping duty cash deposits are not an inevitable consequence of the antidumping duty order and that, with respect to imputed interest costs, there is no real opportunity cost associated with cash deposits when the paying of such deposits is a precondition for doing business in the United States. Further, the Court finds that NTN failed to provide any evidence on record that supports the fact that NTN actually or approximately incurred the alleged interest expenses on antidumping duty cash deposits. Commerce acted rationally in denying NTN’s claimed interest-expense adjustment and, therefore, Commerce’s determination is sustained. VII. Valuation of Major Inputs From Affiliated Suppliers A. Statutory Background The NV of the subject merchandise is, in pertinent part, “the price at which the foreign like product is first sold ... for consumption in the exporting country.” 19 U.S.C. § 1677b(a)(l)(B)(i). However, whenever Commerce has “reasonable grounds to believe or suspect” that sales of the foreign like product under consideration for the determination of NV have been made at prices which represent less than the COP of that product, Commerce shall determine whether, in fact, such sales were made at less than the COP. See 19 U.S.C. § 1677b(b)(l) (1994). A “reasonable ground” exists if Commerce disregarded below-cost sales of a particular exporter or producer from the determination of NV in the most recently completed administrative review. See 19 U.S.C. § 1677b(b)(2)(A)(ii). If Commerce determines that there are sales below the COP and certain conditions are present under § 1677b(b)(l)(A)-(B), it may disregard such below-cost sales in the determination of NV. See id. Additionally, the special rules for the calculation of COP or CV contained in 19 U.S.C. § 1677b(f)(2)-(3) (1994), provide that, in a transaction between affiliated persons as defined in 19 U.S.C. § 1677(33) (1994), Commerce may disregard either the transaction or the value of a major input. Section 1677b(f)(2) provides that Commerce may disregard an affiliated-party transaction when “the amount representing [the transaction or transfer price] does not fairly reflect the amount usually reflected in sales of merchandise under consideration in the market under consideration [that is, an arms-length or market price].” If such “a transaction is disregarded ... and no other transactions are available for consideration,” Commerce shall value the cost of an affiliated-party input “based on the information available as to what the amount would have been if the transaction had occurred between persons who are not affiliated,” that is, based on an arms-length or market value. 19 U.S.C. § 1677b(f)(2) (“fair-value” provision). Section 1677b(f)(3)’s “major input rule” directs that if (1) a transaction between affiliated companies involves the production by one of such companies of a “major input” to the merchandise produced by the other, and (2) Commerce has “reasonable grounds to believe or suspect” that the amount reported as the value of such input is below the COP, then Commerce may calculate the value of the major input on the basis of the data available regarding such COP, if such COP exceeds the market value of the input, as determined under § 1677b(f)(2). For purposes of § 1677b(f)(3), regulation 19 C.F.R. § 351.407(b) (1998) provides that Commerce will value a major input supplied by an affiliated party based on the highest of (1) the actual transfer price for the input, (2) the market value of the input, or (3) the COP of the input. B. Factual Background Because Commerce disregarded sales that failed the below-cost sales test pursuant to § 1677b(b)(l) in the prior review with respect to NTN’s TRBs from Japan, Commerce determined pursuant to § 1677b(b)(2)(A)(ii) that it had “reasonable grounds to believe or suspect” that sales of NTN’s foreign like product under consideration for the determination of NV in this POR might have been made at prices below the COP. See Preliminary Results, 62 Fed.Reg. at 47,457. Consequently, pursuant to § 1677b(b)(l), Commerce initiated COP investigations of NTN’s sales in the home market and, thereby, requested information relating to the COP and CV. See id. In its questionnaire for this POR, Commerce requested that NTN provide certain data regarding the valuation of major inputs received from affiliated suppliers and used to produce the merchandise under review during the cost calculation period. See Def.’s Mem. at 60; see also Def.’s Ex. 4. In particular, Commerce instructed NTN as follows: List the major inp