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Determination of Non Injurious Price

               9.6.18. Format-K (Calculation of Capital Employed):  Format-K indicates the
              details regarding the calculation of capital employed, which forms the basis for
              computation of return. It contains two tables viz., one for the details regarding the
              Working Capital and the other one for Net Fixed Assets. The format requires that
              the details of Components of Working Capital/NFA including NPUC claimed, PUC
              claimed (plant wise) and basis of allocation between PUC and NPUC be furnished
              head wise for company as a whole. An additional information on the impact of
              revaluation of assets, if any, is also to be furnished in the NFA part. The above
              information is used for calculation of average capital employed, which will then be
              used for computation of return. It must be ensured that no return is allowed for
              facilities not deployed on the production of the subject goods. The figures should
              reconcile with the audited/certified records of the company. The following issues
              may merit consideration in this regard:

              (a)    Efforts should be made to identify the direct working capital for the PUC.
                     Sometimes, it is seen that the figures for product wise working capital are
                     not available with the companies and therefore, working capital is worked
                     out for the company as a whole. This figure is then allocated to different
                     products  on  the  basis  of turnover  of  the  respective products  (including
                     captive consumption) or any other appropriate basis. It must be seen in all
                     such cases that the allocation bases adopted are reasonable considering the
                     credit period allowed for each product of the company. Further, the share
                     of working capital is preferably allocated to all the activities of the company
                     including the trading activity, if any. It may be noted here that trading
                     activity of PUC is considered as NPUC only for all injury analysis. The current
                     assets for determination of working capital do not include investments/
                     deposits outside the business. Similarly, huge cash/bank balance/FDR etc.
                     should also be excluded on merits.
              (b)    Sometimes, it is seen that the amount of net working capital works out in a
                     negative figure. This is more prevalent in the case of sick companies or other
                     companies facing a liquidity crunch. The working capital is taken as zero in
                     all such cases and return is allowed on NFA portion only. The terms of loans
                     received or extended to the related parties must also be seen to ensure their
                     reasonability.
              (c)    Efforts should be made to directly identify the assets used for the production
                     of PUC. No impact of revaluation is to be considered for return purposes.




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