Full opinion text
OPINION TSOUCALAS, Senior Judge: Plaintiffs and defendant-intervenors move this Court for judgment on the agency record pursuant to Rule 56.2 of the Rules of this Court. Plaintiffs and defendant-intervenors challenge the Department of Commerce, International Trade Administration’s (“Commerce”) final results of the fourth administrative review for antifriction bearings (“AFBs”), entitled Antifriction Bearings (Other Than Tapered Roller Bearings) and Parts Thereof From France, et al.; Final Results of Antidumping Duty Administrative Reviews, Partial Termination of Administrative Reviews, and Revocation in Part of Antidumping Duty Orders (“Final Results”), 60 Fed.Reg. 10,900 (Feb. 28,1995). Background The fourth administrative review encompasses imports of AFBs entered during the fourth review period of May 1, 1992 through April 30, 1993. See Final Results, 60 Fed. Reg. at 10,900. The present consolidated action concerns imports from Japan. On February 28, 1994, Commerce published the preliminary results of the fourth administrative review. See Antifriction Bearings (Other Than Tapered Roller Bearings) and Parts Thereof From France, Germany, Italy, Japan, Singapore, Sweden, Thailand, and the United Kingdom; Preliminary Results of Antidumping Duty Administrative Reviews, Partial Termination of Administrative Reviews, and Notice of Intent To Revoke Orders (in Part), 59 Fed.Reg. 9,463 (Feb. 28,1994). On February 28,1995, Commerce published the Final Results at issue. See Final Results, 60 Fed.Reg. at 10,900. NSK Ltd. and NSK Corporation (“NSK”) claims Commerce erred in: (1) failing to apply a tax-neutral methodology in computing the value-added tax (“VAT”) adjustment; (2) treating NSK’s return rebates and post-sale price adjustments as indirect selling expenses; (3) denying NSK a direct adjustment to foreign market value (“FMV”) for home market early payment discounts and distributor incentives; (4) rejecting NSK’s lump sum post-sale price adjustments and stock transfer commissions as indirect expenses; (5) not using NSK’s purchase prices for bearings purchased by NSK from related suppliers; (6) improperly calculating exporter’s sales price (“ESP”) for imported bearing parts further manufactured in the United States; (7) rejecting NSK’s reported interest income offset to interest expense in the calculation of cost -of production (“COP”) and constructed value (“CV”); and (8) including zero-priced sample sales in the U.S. database. Koyo Seiko Co., Ltd. and Koyo Corporation of U.S.A. (“Koyo”) contends Commerce erred in: (1) failing to apply a tax-neutral methodology in computing the VAT adjustment; (2) disallowing certain Koyo home market post-sale price adjustments that were not reported on an invoice-or product-specific basis; (3) investigating the cost of inputs obtained by Koyo from related party suppliers; (4) reclassifying Koyo’s non-operating expenses and payments out of retained earnings as production expenses; and (5) committing certain clerical errors. NTN Bearing Corporation of America, American NTN Bearing Manufacturing Corp., NTN Corporation, NTN Driveshaft, Inc. and NTN-Bower Corporation (“NTN”) argues Commerce erred in: (1) failing to apply a tax-neutral methodology in computing the VAT adjustment; (2) including sample sales in the FMV calculation; (3) crossing levels of trade in comparing U.S. and home market sales; (4) refusing to grant NTN a price-based level of trade adjustment; (5) excluding NTN’s home market sales to related parties in FMV calculation; (6) rejecting NTN’s adjustment for interest on selling expenses; (7) reallocating NTN’s U.S. selling expenses based on the sale price to the first unrelated party; (8) making improper adjustments to NTN’s COP and CV data; and (9) treating home market discounts attributable to sales of subject merchandise as an indirect selling expense. Nippon Pillow Block Sales Co., Ltd. and FYH Bearing Units USA (“NPB”) asserts Commerce erred in resorting to best information available when NPB failed to report certain negative billing adjustments. The Torrington Company (“Torrington”) claims Commerce erred in: (1) incorrectly applying the “Roller Chain” and “knowledge” tests to exclude merchandise imported by Honda Motor Co., Ltd., American Honda Motor Co., Inc., Honda of America Mfg., Inc. and Honda Power Equipment Mfg., Inc. (“Honda”); (2) granting billing, post-sale price and warranty credit adjustments that were not linked to specific sales of in-scope merchandise; (3) accepting Koyo’s U.S. freight expenses where air and ocean freight charges were commingled and allocated to all U.S. sales without linkage to specific sales; (4) accepting Koyo’s data regarding “efficiency variances” used in the calculation of cost of production contrary to its own verification; (5) failing to take into account certain related party commissions paid by NTN with respect to purchase price sales; (6) accepting NTN’s designation of certain sales at the “aftermarket” level of trade and NSK’s designation of certain distributor sales as destined to original equipment manufacturers (“OEMs”); and (7) committing certain clerical errors. Discussion The Court’s jurisdiction in this action is derived from 19 U.S.C. § 1516a(a)(2) (1994) and 28 U.S.C. § 1581(c) (1994). The Court must uphold Commerce’s final determination 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). Substantial evidence is “more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 477, 71 S.Ct. 456, 459, 95 L.Ed. 456 (1951) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 216-17, 83 L.Ed. 126 (1938)). “It is not within the Court’s domain either to weigh the adequate quality or quantity of the evidence for sufficiency or to reject a finding on grounds of a differing interpretation of the record.” Timken Co. v. United States, 12 CIT 955, 962, 699 F.Supp. 300, 306 (1988), aff'd, 894 F.2d 385 (Fed.Cir.1990). 1. VAT Adjustment NSK, Koyo and NTN request a remand for Commerce to apply a tax-neutral amount, rather than rate, methodology in computing the VAT adjustment to U.S. price. NSK’s Mem.Supp.Mot.J.Ageney R. at 52-53; Koyo’s Mem.Supp.Mot.J.Agency R. at 8-10; NTN’s Mem.Supp.Mot.J.Agency R. at 47-48. Commerce consents to a remand so that it may apply a tax-neutral methodology. Def.’s Partial Opp’n to Mots.J.Agency R. at 7-10. In light of Federal-Mogul Corp. v. United States, 63 F.3d 1572, 1580 (Fed.Cir.1995), requiring Commerce to apply a tax-neutral methodology, the Court agrees that remand is appropriate. This case is therefore remanded to Commerce to apply a tax-neutral methodology in computing the VAT adjustment to U.S. price for NSK, Koyo and NTN. 2. FMV Adjustments for Various Home Market Post-Sale Adjustments In calculating FMV and U.S. price, Commerce must determine the price actually charged by a respondent for the merchandise at issue, including discounts, rebates and price adjustments. See 19 U.S.C. §§ 1677a & 1677b (1988). Commerce believes the effect of allowing allocations for price adjustments that are averaged over all sales is to distort the actual price paid for each specific sale. Commerce has therefore primarily required respondents to provide transaction-specific information before allowing direct adjustments to FMV for discounts, rebates and post-sale price adjustments (“PSPAs”). Upon denying a direct adjustment to FMV for certain selling expenses directly related to underlying sales, Commerce has allowed certain price adjustments to be allocated as indirect selling expenses under the ESP offset. However, this practice was recently rejected by the United States Court of Appeals for the Federal Circuit (“CAFC”). In Torrington Co. v. United States, 82 F.3d 1039 (Fed.Cir.1996), the CAFC had to determine whether certain PSPAs to FMV were appropriate. The PSPAs at issue involved the correction of invoicing errors and retroactive price changes recorded only on a customer-specific basis. The Court first noted that the determining factor for whether PSPAs qualify for ESP offset treatment is on the PSPA calculation method, not the recordation or allocation method. The Court then found the following: Both kinds of PSPA [at issue] involve adjustments to the price of a product, or group of products, made in response to billing errors for a particular customer or in response to the post-sale raising or lowering of the price for a particular customer. Torrington, 82 F.3d at 1050. The CAFC went on to conclude that, because these PSPAs represent expenses related to a particular sale or sales, they vary with the quantity of the item sold, and so, constitute direct selling expenses. However, the CAFC noted that 19 C.F.R. § 353.56(b)(2) explicitly disallows direct selling expenses from being deducted from FMV as ESP offsets. Torrington, 82 F.3d at 1051 (citing Sharp Corp. v. United States, 63 F.3d 1092, 1096 (Fed.Cir.1995) (stating 19 C.F.R. § 353.56(b)(2) provides for a deduction from FMV for all selling expenses except direct selling expenses)); see also Timken Co. v. United States, 20 CIT -, -, 930 F.Supp. 621, 632 (1996). NSK, NTN, Koyo and Torrington contest Commerce’s treatment of certain post-sale price adjustments in this review. a. NSK’s Adjustments NSK contends Commerce improperly: (1) treated NSK’s return rebate and post-sale price adjustments as indirect selling expenses; (2) denied NSK a direct adjustment to FMV for NSK’s home market early payment discounts and distributor incentives; and (3) rejected NSK’s lump sum post-sale price adjustments and stock transfer commissions as indirect expenses. NSK’s Mem.Supp.Mot.J.Agency R. at 21-34. To retain its Japanese OEM customers that purchased products through distributors yet prevent these distributors from reaping huge profits through sales to aftermarket customers, NSK established a return rebate program. In this program, NSK sells bearings to distributors at a provisional price equal to prices NSK charges to aftermarket customers, but rebates a percentage of this price following proof of the quantities and price charged by the distributor to the OEM. The NSK PSPAs at issue involve the correction of clerical errors, the finalization of a temporary sale price and the price adjustments for changes negotiated subsequent to sale. NSK claims its return rebates and PSPAs should have been treated as direct expenses because they were essentially reported on a transaction-specific basis and, therefore, are directly linked to underlying sales. See NSK’s Mem.Supp.Mot.J.Ageney R. at 23-26; NSK’s Reply Mem.Supp.Mot.J.Ageney R. at 3-6. While NSK concedes that its business records did not allow it to calculate the return rebates on a transaction-specific basis, it maintains that, because its return rebates did not vary during the review period, its methodology adjusted the selling price of each transaction to reflect the rebate actually paid by NSK to the distributor. NSK’s Mem.Supp.Mot.J.Ageney R. at 23. Commerce maintains it properly dealt with NSK’s return rebates and PSPAs as indirect expenses because they were not reported on a transaction-specific basis. Def.’s Partial Opp’n to Mots. J.Agency R. at 15-18. Torrington agrees Commerce should not allow NSK a direct adjustment to FMV for return rebates and PSPAs. Torrington’s Opp’n to Mots.J.Agency R. at 10-14. However, Torrington argues Commerce should not allow even an indirect adjustment to FMV for NSK’s PSPAs because: (1) PSPAs are, by nature, price adjustments incurred on, and inseparable from, specific transactions, not selling expenses incurred on all sales; and (2) allowing PSPAs that do not qualify as direct adjustments to price to be treated as indirect selling expenses is erroneous. Torrington’s Mem.Supp.Mot.J.Ageney R. at 41, 42-45. As a preliminary matter, the case to which Torrington cites for support, RHP Bearings v. United States, 19 CIT -, 875 F.Supp. 854 (1995), is distinguishable, as it deals with technical service expenses in the U.S. market, which are treated differently than PSPAs in the home market. See Torrington Co. v. United States, 17 CIT 672, 684, 832 F.Supp. 365, 376 (1993) (stating Commerce may treat similar expenses differently in the calculation of U.S. price and FMV). Commerce verified that the return rebate program directly related to sales of in-scope bearings to certain distributors, i.e., NSK kept track of sales to each distributor of standard part numbers eligible for the rebate, less resales by the distributor for which a rebate had already been paid. See NSK HM Sales Verification Report, P.R.Doc. No. 342, at 9-10, Def.’s App., Ex. 18, at 9-10 (March 4, 1994). Further, as NSK’s PSPAs normally occur after the original sale, Commerce verified that NSK’s records link these expenses on a product- and customer-specific basis, but not to the exact original sale. Id. at 10-11. Similar to the PSPAs at issue in Torrington, therefore, NSK’s return rebates and PSPAs represent expenses related to particular sales of in-scope merchandise and vary with the quantity of the particular item sold. Wfliile Commerce could not allow these expenses a direct adjustment because of NSK’s failure to tie them to specific transactions and ensure they are not attributable to sales of non-scope merchandise, this does not deprive them of their direct relationship to the sales under consideration. See INA Walzlager Schaeffler KG v. United States, 21 CIT -, -, 957 F.Supp. 251, 267 (1997); Torrington, 20 CIT at -, 926 F.Supp. at 1158. Consequently, pursuant to the CAFC’s decision in Torrington, Commerce improperly treated the expenses as indirect. This case is remanded to Commerce to deny the adjustment to FMV for NSK’s return rebates and PSPAs. NSK further disputes Commerce’s treatment of its early payment discounts, where NSK offered a discount to distributors who paid their invoices before the payment due date, and distributor incentives, where NSK offered payments to distributors as incentives for increases in their sales to approved sub-distributors. NSK’s Mem. Supp. Mot. J. Agency R. at 8, 9. Similar to NSK’s other PSPAs, NSK was unable to link the discounts to individual transactions. Further, NSK calculated the distributor incentive rebates on the basis of sales to all products to distributors, and not on a specific-model basis. Commerce therefore denied direct adjustment to FMV for the early payment discounts and distributor rebate incentives. Final Results, 60 Fed.Reg. at 10,935. NSK claims Commerce improperly denied it a direct FMV adjustment for its early payment discounts and distributor rebate incentives because they were directly related to individual transactions. NSK’s Mem. Supp. Mot. J. Agency R. at 27-31; NSK’s Reply Mem. Supp. Mot. J. Agency R. at 6-9. NSK argues that Commerce, at a minimum, should have granted a direct adjustment for NSK’s sales to four distributors granted discounts as a fixed and constant percentage of sales on all transactions for which they were reported. NSK’s Mem. Supp. Mot. J. Agency R. at 28 (citing Final Results, 60 Fed.Reg. at 10,935). In response, Commerce maintains NSK could not demonstrate that its early payment discounts and distributor rebate incentives did not include discounts or rebates on non-scope merchandise. Hence, they were not entitled to a FMV adjustment. Def.’s Partial Opp’n to Mots. J. Agency R. at 18-20. Torrington agrees generally with Commerce’s rationale in denying the direct adjustment. Torrington’s Opp’n to Mots.J.Agency R. at 15-19. Upon inspection of the record, the Court agrees with Commerce that NSK cannot tie its early payment discounts and distributor incentive rebates to particular sales, and so, the amount to which they are attributable to non-scope merchandise is unclear. This holds true even for the early payment discounts granted to the four distributors to which NSK refers. While Commerce verified that discounts to the four distributors had remained relatively stable during the period of investigation, see Final Results, 60 Fed.Reg. at 10,935, NSK could not tie these discounts to specific transactions, and so, could not ensure what amount was granted to in-seope merchandise. See Torrington, 20 CIT at ---, 926 F.Supp. at 1157-58. Consequently, Commerce properly disallowed a direct adjustment for these expenses. NSK’s final claim involves its lump sum PSPAs, granted on a customer-specific basis, and its stock transfer commissions, where NSK would pay a distributor a commission for purchasing from another distributor a particular part number NSK did not have available. NSK’s Mem. Supp. Mot. J. Agency R. at 10-12. NSK claims Commerce should have treated these expenses as indirect expenses because they did not vary with the quantity of merchandise sold. NSK therefore contends they should have been included in the ESP offset without any requirement that they be linked to in-scope sales. Id. at 31-33; NSK’s Reply Mem. Supp. Mot. J. Agency R. at 10-12. Commerce responds it properly denied the adjustments because they were made on both in-scope and out-of-scope merchandise. Def.’s Partial Opp’n to Mots. J. Agency R. at 20-22. Torrington agrees generally with the position taken by Commerce. Torrington’s Opp’n to Mots. J. Agency R. at 20-24. Pursuant to the CAFC’s decision in Torrington, the Court concludes NSK’s lump sum PSPAs are direct expenses because they account for price changes calculated with respect to a specific customer for a specific period of time. Hence, NSK’s lump sum PSPAs are direct expenses, which may not be the basis for a deduction from FMV pursuant to the ESP offset. See Timken Co. v. United States, 20 CIT at -, 930 F.Supp. at 633. Further, while the stock transfer commissions paid on all products was a fixed percentage of the sales price, NSK could not isolate the percentage of commissions paid to distributors for stock transfers of the subject merchandise between distributors. See NSK Section C Questionnaire Response, P.R.Doc. No. 126, NSK’s App., Ex. 5, at 50-51 (Sept. 29, 1993). Consequently, NSK’s stock transfer commissions are also direct expenses, and so, are not entitled to ESP offset treatment. b. Koyo’s Adjustments (1) Koyo’s PSPAs Koyo originally claimed Commerce improperly disallowed its adjustment to FMV for its PSPAs because Commerce determined they were made or recorded on a lump sum basis and did not distinguish between in-scope and out-of-scope merchandise. Koyo’s Mem. Supp. Mot. J. Agency R. at 10-11 (citing Final Results, 60 Fed.Reg. at 10,931). In light of the CAFC’s decision in Torrington, Koyo has decided to no longer pursue this claim. Koyo’s Reply Mem. Supp. Mot. J. Agency R. at 3. Consequently, Koyo’s claim regarding its PSPAs is dismissed. (2) Koyo’s Warranty Expenses Commerce adjusted for Koyo’s home market warranty expenses as direct expenses pursuant to the COS provision. Final Results, 60 Fed.Reg. at 10,910. Torrington challenges Commerce’s treatment of Koyo’s warranty expense, arguing Koyo did not provide product- or customer-specific warranty credits. Torrington’s Mem. Supp. Mot. J. Agency R. at 41-42. Commerce agrees with Torrington and requests a remand to review the record to determine whether it is possible to remove those portions of Koyo’s warranty expenses which relate to non-scope merchandise from the adjustments to FMV or to deny the adjustment if such removal cannot be made. Def.’s Partial Opp’n to Mots. J. Agency R. at 22-23. Koyo objects to a remand, claiming Commerce’s treatment of its warranty expenses was proper and is distinguishable from the situation involving its PSPAs. Koyo’s Opp’n to-Torrington’s Mot. J. Agency R. at 8-17. Upon inspection of the record, the Court agrees Commerce improperly included Koyo’s warranty expenses relating to non-scope merchandise in adjusting FMV. See Koyo Section C Questionaire Response, P.R.Doc. No. 124, Def.’s App., Ex. 6, at 31-33 (Sept. 29, 1993). The Court therefore remands this issue to Commerce to review the record to determine whether it is possible to remove those portions of Koyo’s warranty expenses which relate to non-scope merchandise from the adjustments to FMV or to deny the adjustment if such removal cannot be made. c. NTN’s Adjustments (1) Home Market Discounts In the Final Results, Commerce treated NTN’s home market discounts as indirect selling expenses. 60 Fed.Reg. at 10,934. NTN asserts Commerce should have treated these discounts as direct selling expenses because it accounted for its discounts using proper product categories, and so, that there was no general pooling of discounts for each customer. NTN’s Mem. Supp. Mot. J. Agency R. at 44-46. Commerce responds it treated the discounts as indirect selling expenses because they were not reported on a transaction-specific basis and because they were not fixed and constant expenses. Def.’s Partial Opp’n to Mots. J. Agency R. at 24-27. Torrington agrees with Commerce’s position. Torrington’s Opp’n to Mots. J. Agency R. at 86-89. The Court concludes that Commerce improperly determined that the discounts at issue are indirect selling expenses. Rather, they are direct selling expenses because they represent expenses related to particular sales of in-scope merchandise. While they are not entitled to a direct adjustment because of NSK’s failure to tie them to specific transactions, this does not deprive them of their direct relationship to the sales under consideration. Therefore, pursuant to the CAFC’s decision in Torrington, this issue is remanded to Commerce to deny the adjustment to FMV for NTN’s home market discounts at issue. (2) Billing Adjustments In the Final Results, Commerce treated certain NTN billing adjustments as direct adjustments to price, stating it had “no reason to believe or suspect that NTN failed to report accurately or completely its [home market] billing adjustments, or that NTN’s method of reporting may have included billing adjustments made on sales of non-subject merchandise.” 60 Fed.Reg. at 10,934-35. NTN claims its total sales value figures were net of billing adjustments, which should have been treated as direct expenses, and asserts Commerce should recalculate NTN’s margins based on sales prices net of billing adjustments. NTN’s Mem. Supp. Mot. J. Agency R. at 46-47. Torrington alleges Commerce improperly treated certain NTN post-sale billing adjustments that had not been reported on a transaction-specific basis as direct adjustments to FMV. Torrington’s Opp’n to Mots. J. Agency R. at 40. Commerce responds that there was no evidence that NTN’s total sales value figures were reported net of billing adjustments, and so, it properly concluded not to make additional adjustments to the individual sales values for billing adjustments in its formula for calculating expenses for each individual sale. Def.’s Partial Opp’n to Mots. J. Agency R. at 24-26. However, Commerce agrees with Torrington and requests a remand to review the record to determine whether it is possible to distinguish between billing adjustments reported on a transaction-specific basis and those reported on a customer-specific or product-specific basis or, if a distinction cannot be made, to treat all NTN’s billing adjustments as indirect selling expenses. Id. at 27. NTN maintains Commerce’s direct price adjustments for its billing adjustments was reasonable. NTN’s Opp’n to Torrington’s Mot. J. Agency R. at 11-12. The Court concludes it is unclear whether NTN’s total sales value figures were reported net of billing adjustments because the evidence on the record does not establish the manner in which NTN calculated the total sales value figure. In essence, there is no specific evidence that all billing adjustments had been accounted for in NTN’s total sales value figure. Hence, Commerce properly declined to make additional adjustments. With respect to Torrington’s claim, certain NTN billing adjustments were indeed not reported on a transaction-specific basis. See NTN Supplemental Section C Questionnaire Response, C.R. Doc. No. 95, Def.’s App., Ex. 28, at 11-12 (Dec. 8,1993). Nevertheless, the relevant issue regarding direct adjustments is ultimately not whether they were reported on a transaction-specific basis, but whether a respondent can demonstrate that its adjustments were not made over non-subject merchandise. See Federal-Mogul Corp. v. United States, 20 CIT -, ---, 950 F.Supp. 1179, 1184-85 (1996) (Commerce properly excluded billing adjustments not recorded on a transaction-specific basis where adjustments on non-scope merchandise could not be removed). Hence, this issue is remanded to Commerce to determine whether the NTN billing adjustments not reported on a transaction-specific basis were made solely over in-scope merchandise and, if so, to allow them a direct adjustment to FMV or, if such a determination cannot conclusively be made, to deny them a direct adjustment to FMV. 3. COP Data of Inputs Obtained from Related Parties a. NSK’s CV Calculation During the review, Commerce used the COP data of inputs that NSK obtained from related parties to determine whether the inputs were sold at arm’s-length. In cases where Commerce concluded that they had not been sold at arm’s-length, Commerce used the COP of the inputs as the “best evidence available” for valuing the inputs. See Final Results, 60 Fed.Reg. at 10,924. NSK contends Commerce is authorized to request COP data for inputs only when it has reason to believe or suspect that the inputs were sold below-COP, which was not the case here. NSK further argues that, in this case, Commerce ignored evidence that the prices negotiated between NSK and its related supplier, Supplier X, fairly reflected market value, i.e., that its inputs were sold at arm’s length prices. NSK’s Mem. Supp. Mot. J. Agency R. at 34-43. In addition, NSK claims Commerce illegally coerced NSK to place COP information for finished bearings purchased from related suppliers on the record because it feared another application of best information available (“BIA”). Id. at 43. Commerce responds that it was authorized to request NSK’s COP data pursuant to 19 U.S.C. § 1677b(e)(2) and the Court’s decision in NSK Ltd. v. United States, 19 CIT -, 910 F.Supp. 663 (1995). Def.’s Partial Opp’n to Mots.J.Agency R. at 32-35. Commerce further maintains that, even if it is authorized to request COP data of inputs only when it has reason to believe or suspect that the inputs were sold at below-COP, it had such grounds in this case due to its conclusions in the third review. Id. at 34-35 (citing Final Results, 60 Fed.Reg. at 10,924). Further, Commerce claims it is not required to consider subjective facts regarding the dealings between NSK and Supplier X before resorting to the COP of an input for that input’s market value. Id. at 37-38. Commerce was authorized to request cost data to determine whether the transfer prices were at arm’s length pursuant to 19 U.S.C. § 1677b(e)(2). Pursuant to the relevant statutes, Commerce must determine whether transfer prices are at arm’s-length. See id. Commerce does this by comparing the transfer prices to: (1) the prices that the related suppliers charge to unrelated parties; and (2) the prices charged by unrelated suppliers to the respondent. If a transaction is disregarded because a respondent cannot establish that it was made at arm’s-length, and there are no other such arm’s-length prices to compare with the transfer prices for components, pursuant to 19 U.S.C. § 1677b(e)(2), Commerce is to rely on the best evidence available to determine the value of the element of value. See NSK, 19 CIT at ---, 910 F.Supp. at 669-70. In the third review period, where NSK also relied upon transfer prices, this Court concluded the following: If based on the information considered, Commerce finds that transfer prices do not “fairly reflect the amount usually reflected in sales in the market under consideration,” then Commerce may disregard these transactions in favor of the best evidence available if “there are no other transactions available for consideration.” ... 19 U.S.C. § 1677b(e)(2) provides a basis for Commerce to request cost data about parts purchased from related suppliers as long as the respondents reported or relied on transfer prices. Thus, 19 U.S.C. § 1677b(e)(2) applies in the case at bar because NSK reported transfer prices in its ... questionnaire response. Id. 910 F.Supp. at 669 (citations omitted). In NSK, therefore, the Court found Commerce properly requested COP data pursuant to 19 U.S.C. § 1677b(e)(2) since the respondent reported and relied upon transfer prices. Id. at 669-70. As in NSK, in this case NSK provided no information regarding prices from unrelated parties upon which to determine the market value for inputs it purchased from related suppliers but, rather, reported and relied upon transfer prices. See Final Results, 60 Fed.Reg. at 10,924. Hence, Commerce had the authority to request COP data under 19 U.S.C. § 1677b(e)(2). It is further clear to this Court that, when there are no purchases of inputs from unrelated suppliers, Commerce may reasonably base the market value of inputs on the COP of inputs. In this case, Commerce used NSK’s COP data without addressing record evidence regarding whether NSK’s purchases from Supplier X were at market value, asserting in its brief that it “appropriately concluded that subjective facts regarding the dealing between NSK and supplier X were not relevant to its determination.” Def.’s Partial Opp’n to Mots.J.Agency R. at 38. Under the statute, Commerce is not required to examine the subjective information relating to the dealings between NSK and its related suppliers over evidence that prices between related parties were not at arm’s-length. Indeed, 19 U.S.C. § 1677b(e)(2) contemplates a comparison of the amount representing an element of value and the amount usually reflected in sales of the merchandise in the market. As Commerce explained in the Final Results, “[flacking information as to what the market value is, we rely on the related supplier’s cost as a measure of the commercial value of that input.” 60 Fed.Reg. at 10,924. The Court finds this process reasonable and in accordance with law. Finally, NSK’s claim that it placed COP information on the record for finished bearings from related suppliers because it feared another application of BIA, and so, such data was “illegally coerced” is without merit. In NSK, 19 CIT at -, 910 F.Supp. at 671, the Court found Commerce improperly resorted to BIA for finished bearings purchased from related suppliers. Unlike the third review, Commerce did not resort to BIA in this case but, rather, used NSK’s COP information. See Final Results, 60 Fed.Reg. at 10,924. Despite NSK’s reasons for including this COP information on the record, Commerce may properly rely on such information once it is on the record. Consequently, the Court concludes that Commerce properly requested and used COP data for inputs that NSK obtained from related suppliers. b. Koyo’s CVCalculation Koyo claims Commerce lacked authority to request COP data of inputs Koyo obtained from related parties, and maintains Commerce may only request such data under § 1677b(e)(3) when Commerce has reason to believe or suspect that the inputs were sold below cost. Pursuant to the above reasoning regarding NSK’s inputs, and in accordance with NSK, 19 CIT at ---, 910 F.Supp. at 669-70, the Court concludes Commerce had the authority to request Koyo’s COP data at issue. 4. ESP Calculation for NSK Parts Further Manufactured in the U.S. During the review, Commerce calculated ESP pursuant to section 1677a(e)(3) for NSK’s AFB parts that were further manufactured in the U.S. prior to their sale to the first unrelated purchaser as completed AFBs. Section 1677a(e)(3) states that if an ESP transaction is involved and the imported merchandise has been further manufactured in the U.S. before the sale to the first unrelated purchaser, then ESP must be reduced by the increased value, including labor and materials, incurred by the additional U.S. manufacturing or assembly. See 19 U.S.C. § 1677a(e)(3). NSK contends that, according to the legislative history, Section 1677a(e)(3) applies only to products covered by an anti-dumping duty order that are further manufactured in the U.S. into non-scope merchandise containing a significant amount of the in-scope imported product. NSK therefore maintains that Commerce should have based margins for imported parts on the margins calculated for finished bearings of the same class or kind. NSK’s Mem.Supp.Mot.J.Agency R. at 44-47. In response, Commerce maintains its use of 19 U.S.C. § 1677a(e)(3) to calculate ESP for NSK’s further manufactured AFB parts is supported by the statutory language and the ease law. Def.’s Partial Opp’n to Mots.J.Agency R. at 41-48. In support of its position, NSK points to the House of Representatives committee report on the section, which states the following: This amendment provides that whenever ... (there is an ESP situation), and the merchandise is changed by further process or manufacture so as to remove it from the class or kind of merchandise involved in the proceeding before it is sold to an unrelated purchaser, such merchandise will not escape the purview of the law____ ... [T]his amendment shall be applicable only if the manufactured or assembled product that is sold to an unrelated person contains more than an insignificant amount of the imported merchandise. H.R.Rep. No. 571, 93d Cong., 1st Sess. 70 (1973) (emphasis added); see also S.Rep. No. 1298, 93d Cong., 2d Sess. 172-73 (1974). NSK’s position, while somewhat supported by the language of the legislative history, is incorrect. First, the Court is to use legislative history to ascertain Congress’s intent where a statute is ambiguous, but not to introduce ambiguity where statutory language is clear. See Terumo Corp. v. United States, 8 CIT 44, 46, 1984 WL 6074 (1984); see also Connecticut Nat’l Bank v. Germain, 503 U.S. 249, 253-54, 112 S.Ct. 1146, 1149-50, 117 L.Ed.2d 391 (1992) (“We have stated time and again that courts must presume that a legislature says in a statute what it means and means in a statute what it says there. When the words of a statute are unambiguous, then, this first canon is also the last: ‘judicial inquiry is complete.’”) (Citations omitted). In this case, the statute is abundantly clear as to its intent: to reduce the price to the first unrelated purchaser in calculating ESP for an imported product that has been further processed. Hence, it is not necessary for the Court to refer to the legislative history. Nevertheless, the legislative history does not directly address the situation at issue here, where the imported scope merchandise is further manufactured or assembled into scope merchandise. Rather, it sets forth Congress’ intent that a further-processed scope part used in non-scope merchandise cannot escape the application of the dumping law unless the imported scope part comprises an insignificant amount of the non-scope merchandise. Hence, the legislative history does not preclude the application of the section to situations where the ultimate product sold is in scope. Indeed, the employment of NSK’s interpretation of the statute would permit minor processing to exempt imports from an antidumping order, thus thwarting the purpose of the antidumping law. Further support for the Court’s position is found in NSK’s challenge to the second review, where this Court concluded, and the CAFC recently affirmed, that Section 1677a(e)(3) covers imported parts utilized in the production of AFBs, and so, the parts are subject to a further-manufacturing analysis. See NSK Ltd. v. United States, 19 CIT -, ---, 896 F.Supp. 1263, 1268-71 (1995), aff'd in part and rev’d in part, 115 F.3d 965, 977-78 (Fed.Cir.1997). See also NSK, 19 CIT at -, 910 F.Supp. at 677; Koyo Seiko Co. v. United States, 18 CIT 740, 747, 861 F.Supp. 108, 114-15 (1994) (imported AFB parts further assembled in U.S. qualify as additional material and labor and require an adjustment for further processing under Section 1677a(e)(3)). The Court therefore concludes that Commerce’s interpretation is reasonable and carries out the congressional intent of reducing the price to the first unrelated purchaser of a further processed import. Consequently, Commerce properly used 19 U.S.C. § 1677a(e)(3) to calculate ESP for NSK’s imported parts that were further-processed into completed AFBs in the U.S. 5. NSK’s Claimed Interest Income Offset to Interest Expense In calculating COP and CV during the review, Commerce denied NSK’s claimed interest income offset to interest expense and resorted to BIA. Final Results, 60 Fed.Reg. at 10,928-29. NSK claims that, in doing so, Commerce departed from its standard practice. Commerce responds it resorted to BIA because NSK failed to explain how its reported interest income offset was related to its bearing manufacturing operations. Def.’s Partial Opp’n to Mots.J.Agency R. at 48-52. Commerce points to the following problems with NSK’s methodology, which it noted in the Final Results: (1) NSK applied a ratio of short-term versus long-term investments to total interest income; and (2) NSK failed to link short-term interest income to business operations. See id. (citing 60 Fed.Reg. at 10,929). Torrington agrees that Commerce properly denied NSK’s interest income offset because NSK failed to substantiate its alleged short-term interest income. Torrington’s Opp’n to Mots. J.Agency R. at 37-43. The Court concludes Commerce’s denial of NSK’s reported interest income offset to interest expense is proper. This Court has recognized Commerce’s practice of limiting interest income offset to interest expense for income items shown to have been earned from the general operations of the company in calculating COP and CV. See NTN Bearing Corp. v. United States, 19 CIT -, ---, 905 F.Supp. 1083, 1096-97 (1995); Timken v. United States, 18 CIT 1, 9, 852 F.Supp. 1040, 1048 (1994). During verification in this case, NSK provided a non-eonsolidated “detail of interest income.” See NSK COP/CV Verification, C.R.Doc. No. 147, Def.’s App., Ex. 23. Although this document provided a general description of the types of short-term assets that had generated its income, it did not provide a list of the actual accounts or explain the nexus between the interest income and NSK’s bearing manufacturing operations. Consequently, in accordance with the court-approved methodology, Commerce properly denied NSK’s reported interest income offset and resorted to BIA. 6. Inclusion of NSK’s U.S. Zero-Priced Sample Transfers Commerce included NSK’s zero-priced sample transfers to U.S. customers in NSK’s U.S. sales database for the margin calculation. Final Results, 60 Fed.Reg. at 10,948. NSK contends the samples in question cannot be considered sales because there was no exchange of monetary consideration. NSK’s Mem.Supp.Mot.J.Agency R. at 50-51. In NSK, Ltd. v. United States, 20 CIT -, -, Slip Op. 96-50, at 6, 1996 WL 109429 (1996), this Court upheld Commerce’s inclusion of NSK’s zero-priced sample transfers because excluding such merchandise “creates a loophole in the antidumping law allowing the lowest priced U.S. transactions to escape review and threatens the effectiveness of the law.” The CAFC recently addressed this issue and reversed the Court’s decision in NSK concluding that NSK’s transfers of free samples to potential U.S. customers did not amount to sales. NSK 115 F.3d at 973-76. The CAFC reasoned that Congress intended to give the term “sale” its ordinary meaning, hence precluding NSK’s free samples from being treated as sales because they lacked consideration and because there was no evidence that the potential customers had any obligation regarding the samples but, rather, “were free to transact with NSK based solely on their whim.” Id. at 975. In light of NSK, 115 F.3d at 973-76, the Court has no alternative but to find that NSK’s free samples to U.S. customers in this case were not sales. This issue is therefore remanded to Commerce to exclude NSK’s zero-priced sample sales from NSK’s U.S. sales database. 7. Inclusion of NTN’s Home Market Sample and Similar Transfers NTN claims Commerce should have excluded NTN’s sample and other similar transfers from its home market database because they were made outside the ordinary course of trade. NTN’s Mem. Supp. Mot. J. Agency R. at 14-16. Pursuant to the CAFC’s recent decision in NSK, 115 F.3d at 973-76, sample transfers do not amount to sales under the dumping statute because there is typically no consideration involved. Similar to NSK’s samples in this review, there is no evidence that NTN’s sample transfers involved consideration in this case. Consequently, the Court concludes Commerce improperly included NTN’s sample and other similar transfers in NTN’s home market database and remands to Commerce to exclude them from the FMV calculation. 8. Koyo’s Now-Operating Expenses During the review, Commerce reclassified certain Koyo non-operating expenses and payments out of retained earnings as production expenses. Final Results, 60 Fed.Reg. at 10,926. Koyo claims this reclassification was improper because the expenses at issue were not related to domestic production. Koyo further contends Commerce’s reclassification is contrary to Commerce’s prior practice. Koyo’s Mem. Supp. Mot. J. Agency R. at 17-23. Commerce agrees a remand is necessary to allow Koyo to submit documentation showing that the nature of the expenses Koyo characterized as non-operating is appropriate. Def.’s Partial Opp’n to Mots. J. Agency R. at 56-57. Torringtori maintains Commerce properly reclassified the expenses and claims Koyo’s management had ample opportunity to explain the various categories for expenses at verification. Torrington’s Opp’n to Mots. J. Agency R. at 53-56. Upon review of the record, the Court agrees with Commerce that the record contains insufficient data upon which to determine the exact nature of the expenses at issue. Consequently, this issue is remanded to Commerce to reopen the record to allow Koyo to submit documentation showing the nature of the expenses Koyo characterized as non-operating expenses. 9. Treatment of NTN’s AFB Sales Sold at Different Levels of Trade a. Comparison of Sales Across Different Levels of Trade Under 19 U.S.C. § 1677b(a)(4)(B), Commerce must compare a U.S. price and FMV that are free of distortion caused by “other differences in circumstances of sale.” To account for one such distortion, differing levels of trade, Commerce normally calculates FMV and U.S. price based on sales at the same commercial level of trade. See 19 C.F.R. § 353.58. NTN claims Commerce erred in comparing merchandise across levels of trade because it did not explain its decision to cross levels of trade and did not consider the commercial value of the merchandise sold at various levels of trade. NTN’s Mem. Supp. Mot. J. Agency R. at 16-18. Commerce responds that it compared sales at different levels of trade because it failed to match “such or similar” merchandise at the same level. Commerce further maintains that it properly considered commercial value by applying its twenty percent cost test. Def.’s Partial Opp’n to Mots. J. Agency R. at 60-63. Commerce may cross levels of trade when sales at the same level of trade are not available. See 19 C.F.R. § 353.58; see also NTN Bearing Corp. v. United States, 17 CIT 1149, 1153-55, 835 F.Supp. 646, 650 (1993). The Court concludes Commerce adequately explained its decision to cross levels of trade, as it used language virtually identical to that upheld in NTN, 19 CIT at ---, 905 F.Supp. at 1092-93. Compare Final Results of Antidumping Duty Administrative Reviews and Revocation in Part of an Anti-dumping Duty Order, 58 Fed.Reg. 39,729, 39,767-68 (July 26, 1993) (“AFBs III”) with Final Results, 60 Fed.Reg. at 10,940. In particular, Commerce noted the following: “[W]hen we were unable to compare NTN’s U.S. sales to [home market] sales at the same level of trade, we attempted to find matches at the next most similar level of trade.” Final Results, 60 Fed.Reg. at 10,940. The Court further concludes Commerce properly considered commercial value in selecting sales for comparison. In matching U.S. and home market models in this case, Commerce applied its twenty percent cost test, using the CV of the U.S. model as the basis for FMV where “the difference between the variable manufacturing costs of the U.S. and home market models exceeded 20 percent of the total manufacturing cost of the U.S. model.” NTN Preliminary Analysis Memorandum, P.R.Doc. No. 309, Fiche 135, Frame 33 (Feb. 24, 1994). As this Court determined in NTN, Commerce’s twenty percent cost test appropriately considers commercial value for matching purposes. See NTN, 19 CIT at -, 905 F.Supp. at 1092. b. Denial of Level of Trade Adjustment When Commerce compares sales at differing levels of trade, it is authorized to make a COS adjustment to FMV. See 19 U.S.C. § 1677b(a)(4)(B). Pursuant to the implementing regulation, 19 C.F.R. § 353.56(a)(1), Commerce may make such an adjustment for a bona fide difference in the circumstances of the sales compared. To ensure respondents do not have an incentive to destroy or fail to produce information supporting or rebutting their own assertions, the party claiming such an adjustment has the burden of substantiating its claim. Timken Co. v. United States, 11 CIT 786, 804, 673 F.Supp. 495, 513 (1987). In this case, NTN produced several documents allegedly supporting its claim for a level of trade adjustment. Nevertheless, Commerce concluded that “NTN ... failed to demonstrate what portion, if any, of those price differences [between merchandise sold at different levels of trade] is attributable to differences in levels of trade,” as opposed to other factors. Final Results, 60 Fed.Reg. 10,940. NTN argues Commerce erred in denying NTN a level of trade adjustment to FMV to compensate for the different prices at each level of trade and requests a remand for Commerce to explain its conclusion. NTN’s Mem.Supp.Mot.J.Agency R. at 18-23. Commerce responds that the information NTN provided failed to adequately quantify the portion of the price differences attributable to differences in the levels of trade, and so, NTN did not demonstrate that it was entitled to a level of trade adjustment. Def.’s Partial Opp’n to Mots.J.Agency R. at 63-69. Torrington agrees generally with the position taken by Commerce. Torrington’s Opp’n to Mots.J.Agency R. at 67-69. Despite Commerce’s somewhat conelusory statement in the Final Results, upon inspection of the record, it is clear to this Court that NTN failed to substantiate its claim for a level of trade adjustment to FMV. As Commerce and Torrington point out in their briefs, NTN could have shown that the price differentials it indicated were due to selling expenses attributable directly to differences in the levels of trade, as opposed to differences in, for instance, quantities sold, arbitrary pricing practices, credit costs, freight, packing or other factors. See Def.’s Partial Opp’n to Mots.J.Agency R. at 66; Torrington’s Opp’n to Mots.J.Agency R. at 68. The information NTN submitted, however, merely indicated variances in prices and selling expenses at the different levels of trade, without illustrating the factors to which they were attributable. See, e.g., NTN’s Section A Questionnaire Response, C.R.Doc. No. 5, Def.’s App., Ex. 21 (Aug. 10, 1993) (reporting percentage differences in prices depending on the level of trade at which merchandise was sold). NTN argues that Commerce has not indicated what proof would suffice for a level of trade adjustment. However, in American Permac, Inc. v. United States, 12 CIT 1134, 1138, 703 F.Supp. 97, 101 (1988), upon which NTN relies, the Court held that respondent’s detailed sales information regarding U.S. sales and a third market sale, as well as a detailed accounting study of expenses for home market sales where such information did not exist, was enough to support the respondent’s claim. As indicated above, NTN did not provide such necessary information in this ease. See also NTN, 19 CIT at ---, 905 F.Supp. at 1093-94 (denying level of trade adjustment claim based on similar information). Consequently, Commerce’s decision to deny NTN’s claimed level of trade adjustment was supported by evidence on the record and fully in accordance with law. c. Reallocation of NTN’s Selling Expenses Without Regard to Level of Trade and Denial of a Level of Trade Adjustment Based on Indirect Selling Expenses NTN argues Commerce improperly denied NTN’s request for a level of trade adjustment based on differences in selling expenses despite evidence demonstrating that sales made at different levels of trade incurred different selling expenses. NTN acknowledges that the Court decided this same issue in a challenge to the third review, see NTN, 19 CIT at ---, 905 F.Supp. at 1094-95, but maintains the facts on this record provide greater support for its position. NTN’s Mem.Supp.Mot.J. Agency R. at 21-23. After a thorough review of the record, the Court concludes that the facts in this ease are substantially the same as those in the third review. The evidence on the record does not establish differences in selling expenses at the three levels of trade because NTN’s allocation methodology again does not reasonably quantify the expenses incurred at each level of trade. Commerce explained the following in the Final Results: [NTN’s and NTN-Germany’s] expenses are fixed period costs that do not vary according to sales value or the number of employees who allegedly sell each type of merchandise. Further, ... NTN’s and NTN-Germany’s allocations according to levels of trade [are] misplaced because the types of expenses that they allocated are indirect selling expenses that typically relate to all sales. 60 Fed.Reg. at 10,940. Hence, the Court finds no reason to depart from its decision in NTN, 19 CIT at ---, 905 F.Supp. at 1094-95. Commerce properly denied NTN’s request for a level of trade adjustment based on differences in selling prices at the three levels of trade. 10. Exclusion of Certain NTN Home Market Sales to Related Parties Under the relevant statute, Commerce may base FMV on the price paid by a related party. See 19 U.S.C. § 1677b(a)(3). However, Commerce usually excludes related party sales unless a respondent demonstrates to Commerce’s satisfaction that a related party price is an arm’s-length price, i.e., that the related party prices are “comparable” to unrelated party prices. See NTN, 19 CIT at -, 905 F.Supp. at 1099 (citing 19 C.F.R. § 353.45(a)); see also NEC Home Elecs., Ltd. v. United States, 18 CIT 336, 338-39, 1994 WL 176914 (1994), aff'd in part and rev’d in part, 54 F.3d 736, 744 (Fed.Cir.1995). In this case, NTN reported both related and unrelated sales, admitting that prices for two classes or kinds of related sales, ball and cylindrical roller bearings, were lower than unrelated party prices while related party prices of spherical roller bearings were actually higher than unrelated party prices. See Final Results, 60 Fed.Reg. at 10,946-47. Commerce developed a weighted-average percent difference in pricing for each class or kind of merchandise and discarded sales to related parties where the related party average price was lower than unrelated party price. See id. NTN challenges Commerce’s methodology, arguing that Commerce failed to provide an objective basis for determining when prices are comparable and that Commerce should have used other factors in determining whether to use sales to related parties when calculating FMV. NTN further contends, with the aid of a hypothetical example, that Commerce should not have used weighted-average prices in determining comparability. NTN’s Mem.Supp.Mot.J.Agency R. at 23-26. Under the applicable statute, Commerce is allowed considerable discretion in deciding whether to include related party sales when calculating FMV. Usinor Sacilor v. United States, 18 CIT 1155, 1158, 872 F.Supp. 1000, 1004 (1994). For instance, in NTN, 19 CIT at -, 905 F.Supp. at 1100, this Court upheld Commerce’s arms’-length test, emphasizing that respondents failed to present “record evidence tending to show that ... Commerce’s test was unreasonable.” In this case, NTN has merely restated its position and has not presented any evidence that would require a different conclusion. This Court has also rejected the contention that Commerce should consider other factors (ie., factors other than price) in determining comparability and finds no reason to depart from its stated position. See NTN, 19 CIT at -, 905 F.Supp. at 1100. In addition, NTN’s hypothetical example supporting its claim that Commerce should not have used weighted-average prices in determining comparability fails to prove that Commerce’s test is unreasonable, as it does not constitute record evidence demonstrating that its related party prices were comparable to its unrelated party prices. The Court therefore concludes that Commerce’s methodology, including its decision to use weighted averages, is within its discretion and Commerce need not consider other factors. See id. 11. NTN’s Imputed Interest Expense Allocation NTN claims that Commerce improperly denied NTN’s claimed offset for interest expenses incurred in financing cash deposits of estimated antidumping duties. NTN’s Mem.Supp.Mot.J.Agency R. at 26-30. Commerce consents to a remand to conform this issue with the remand redetermination pursuant to Federal-Mogul Corp. v. United States, 20 CIT -, ---, 918 F.Supp. 386, 412-13 (1996). Def.’s Partial Opp’n to Mots.J.Agency R. at 79-80. Torrington, however, maintains that Commerce properly rejected NTN’s claimed adjustment. Torrington’s Opp’n to Mots.J.Agency R. at 74-77. In the remand results to the third administrative review, Commerce determined, and the Court agreed, that it had properly allowed NTN’s imputed interest expense adjustment because the expense could not be categorized as a selling expense. See Federal-Mogul, 20 CIT at ----, 950 F.Supp. at 1182-83. In light of Federal-Mogul, this issue is remanded to Commerce, to allow NTN’s adjustment for interest expenses on antidumping duty cash deposits. 12. Reallocation of NTN’s U.S. Selling Expenses Based on the Sale Price to the First Unrelated Purchaser In prior reviews, Commerce accepted NTN’s reported U.S. selling expenses allocated on the basis of the transfer prices between NTN-Germany and NTN Bearing Corporation of America. See, e.g., AFBs III, 58 Fed.Reg. at 39,749 (third review final results). Nevertheless, in this review, Commerce chose to reallocate the expenses using the resale prices to the first unrelated purchasers. See Final Results, 60 Fed.Reg. at 10,919. NTN claims Commerce inexplicably deviated from its previous methodology in reallocating the expenses, contrary to the principles articulated in Shikoku Chems. Corp. v. United States, 16 CIT 382, 795 F.Supp. 417 (1992). NTN further alleges Commerce’s reallocation yields less accurate results than the previous methodology. NTN’s Mem.Supp.Mot.J.Ageney R. at 30-31. To sustain Commerce’s choice of methodology, the Court must determine whether the methodology is reasonable, and not whether it is the only reasonable one, or even the one that the Court finds most reasonable. See Ceramica Regiomontana, S.A. v. United States, 10 CIT 399, 404-05, 636 F.Supp. 961, 966 (1986), aff'd, 810 F.2d 1137 (Fed.Cir.1987); see also NTN, 19 CIT at -, 905 F.Supp. at 1100 (stating the Court will uphold the test that Commerce selects to measure whether sales to related parties were made at arms’-length unless that test is shown to be unreasonable). In this case, Commerce allocated expenses using resale prices to unrelated parties, noting that such a methodology provides a value that is not subject to potential manipulation by respondents. See Final Results, 60 Fed.Reg. at 10,919. Based on this rationale, and despite the fact that Commerce had previously used a different methodology, the Court concludes that Commerce’s new methodology is reasonable. First, the present situation is distinguishable from Shikoku. The Shikoku court decided that the methodology Commerce used in the investigation and four administrative reviews had become the law of the proceeding, and so, Commerce could not deviate from that methodology. 16 CIT at 387, 795 F.Supp. at 422. The court emphasized record evidence that plaintiffs adjusted their prices in accordance with the methodology Commerce had consistently applied in the investigation and previous four reviews. Id. As this Court recently stated in rejecting a similar argument from NTN, “[ijmportantly, in Shikoku, plaintiffs established their reliance on Commerce’s previous methodology consistently applied in several reviews.” NTN, 19 CIT at -, 905 F.Supp. at 1095; see also Koyo Seiko Co. v. United States, 20 CIT -, -, 936 F.Supp. 1040, 1044 (1996). The Court is disturbed that Commerce would change its consistent methodology in this review, especially after rejecting, as mere speculation, Torrington’s argument that the prices were subject to manipulation. See 60 Fed.Reg. at 10,919. Nevertheless, Commerce’s methodology is reasonable and NTN has not demonstrated any detrimental reliance, such as that in Shikoku, on Commerce’s previous methodology. Further, NTN failed in any way to support its contention that Commerce’s reallocation yields less accurate results than the previous methodology- Consequently, Commerce’s decision in this case to reallocate NTN’s selling expenses based on the sales price to the first unrelated purchaser is reasonable. 13. Adjustments to NTN’s COP and CV During the review, Commerce submitted to NTN a supplemental questionnaire requesting NTN to provide, among other things, a detailed description and an example of the sample calculations presented in NTN’s original questionnaire exhibit for standard costs. At verification, NTN presented a business proprietary worksheet listing actual costs by product line in one of its plants that Commerce subsequently determined was inconsistent with NTN’s prior representations. According to Commerce, the worksheet demonstrated that NTN had overstated the standard costs of non-scope merchandise, and so, had understated the standard costs of scope merchandise. Commerce therefore adjusted NTN’s reported COP and CV. See Final Results, 60 Fed.Reg. at 10,928-29. NTN claims the adjustment was not warranted for several reasons: (1) the basis for the adjustment was a worksheet that was not a regularly maintained business record and that concerned actual costs prior to the review for one plant, with an insignificant portion of the plant’s production forming the basis of the adjustment; (2) Commerce drew erroneous conclusions about revisions in standard costs for subject and non-subject merchandise; and (3) Commerce did not have a legal basis to resort to BIA. See NTN’s Mem.Supp.Mot.J.Agency R. at 32-40. NTN further alleges that, assuming the adjustment was warranted, Commerce’s methodology for calculating the adjustment is less accurate than a methodology that could have been employed. Id. at 42-43. Commerce responds that all of NTN’s claims are without merit. While Commerce admits that the worksheet in question was not a regular business document, it insists that NTN did not offer Commerce such a document that could have been used to test NTN’s standard costs. Further, while the worksheet information was based on costs prior to the period of review, Commerce notes that standard costs are based on historical information that is occasionally updated. In