Page 356 - MANUAL OF SOP

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

332