Page 355 - Manual Of SOP
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Manual of OP for Trade Remedy Investigations


                     with the annual weighted average price reflected in Appendix-6 to ensure
                     that the weighted average price does not vary widely from the purchase
                     price as per sample invoice. If it varies widely, reasons of such variations may
                     be ascertained;

               (viii)   Sometimes, the procurement rates vary widely from day to day or month to
                     month. The monthly consumption rate may need to be worked out in such
                     a case with scope for monthly/quarterly COP;
               (ix)   Allocation and Apportionment of expenses as indicated in Appendix-7 is
                     one of the most critical tasks for costing. The same methodology needs
                     to be applied in case of Appendix-5 also. There is one format for one PUC
                     for the entire company in any investigation. Different units are reflected by
                     way of creating multiple columns in the same format. In other words, if a
                     company has three units manufacturing the PUC, separate column shall be
                     created in this Format for each such entity. This facilitates separate COP
                     for each of the units based on its own efficiency and performance. The
                     expense heads are indicative and can be changed/modified based on the
                     uniqueness of any investigations. It may be added that separate columns
                     need to be added for each major utility and captively consumed product
                     to ensure verification and availability of complete details. This also ensures
                     that the pricing of all inputs is at arm’s length pricing. The following are the
                     major points to be seen:
                     (a)    The revenue and expenditure of the company as a whole as per
                            audited accounts/certified records is reconciled with expenses for the
                            company as a whole. The expenses are then allocated/apportioned
                            to various plants producing PUC, common utilities and non-PUC etc.
                            There will preferably be a separate column for each major common
                            utility. Major captive inputs/utilities should have separate columns to
                            help verification of their costs. These common utilities and captive
                            consumptions are then apportioned to PUC/Non-PUC through
                            secondary allocation. The basis of allocation should be as direct as
                            possible, and a reasonable one, which is consistently followed by the
                            company;
                     (b)    The  basis  of  allocation  adopted  for  allocation  or  apportionment
                            of common expenses or joint expenses is very critical for the COP





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