NOTICES DEPARTMENT OF COMMERCE International Trade Adminstration Certain Iron-Metal Castings From India; Preliminary Results of Countervailing Duty Administrative Review Tuesday, October 7, 1986 *35676 AGENCY: International Trade Administration/Import Administration, Department of Commerce. ACTION: Notice of preliminary results of countervailing duty administrative review. SUMMARY: The Department of Commerce has conducted an administrative review of the *35677 countervailing duty order on certain iron-metal castings from India. The review covers the period January 1, 1984 through December 31, 1984 and ten programs. As a result of the review, the Department has preliminarily determined the net subsidy to be 6.99 percent ad valorem during the period of review. Interested parties are invited to comment on these preliminary results. EFFECTIVE DATE: October 7, 1986. FOR FURTHER INFORMATION CONTACT: Susan Silver or Bernard Carreau, Office of Compliance, International Trade Administration, U.S. Department of Commerce, Washington, DC 20230; telephone: (202) 377-2786. SUPPLEMENTARY INFORMATION: Background On October 18, 1984, the Department of Commerce ("the Department") published in the Federal Register (49 FR 40943) the final results of its last administrative review of the countervailing duty order on certain iron-metal castings from India (October 16, 1980, 46 FR 16921). On October 15, 1985, the petitioner, Pinkerton Foundry, Inc., requested in accordance with § 355.10 of the Commerce Regulations an administrative review of the order. We published the initiation of the administrative review on November 12, 1985 (50 FR 46689). The Department has now conducted that administrative review in acordance with section 751 of the Tariff Act of 1930 ("the Tariff Act"). Scope of Review Imports covered by the review are shipments of Indian manhole covers and frames, clean-out covers and frames, and catch basin grates and frames. Such merchandise is currently classifiable under items 657.0950 and 657.0990 of the Tariff Schedules of the United States Annotated. The review covers the period January 1, 1984 through December 31, 1984 and ten programs: (1) The International Price Reimbursement Scheme ("IPRS"); (2) A rebate upon export of indirect taxes under the Cash Compensatory Support program ("CCS"); (3) Pre-shipment export loans; (4) Income tax deductions; (5) Grants through the Market Development Assistance program; (6) The sale of Import Replenishment Licenses; (7) Extension of the free trade zones; (8) Supply of raw materials at preferential prices; (9) Preferential freight rates; and (10) Import duty exemptions available to 100 percent export- oriented units. Analysis of Programs (1) IPRS Program On February 9, 1981, the Government of India introduced the International Price Reimbursement Scheme ("IPRS") for exporters of products with steel inputs. The purpose of the program is to rebate the difference between higher domestic and lower international prices of steel. On September 28, 1983, the Indian government extended the IPRS to include pig iron inputs. The funds for the rebate come from a levy on domestic steel and pig iron that is paid by all purchasers of those products. The Joint Plant Committee ("JPC"), a government- directed organization comprised largely of pig iron and steel producers, sets domestic pig iron and steel prices and determines that specific levy for each pig iron and steel product based on the anticipated need for each of those inputs in exported products. The rebate is based on the differential between domestic and international prices and a standard factor for the consumption of each of those inputs in the final product. Castings exporters obtained IPRS rebates for pig iron during the period of review. We consider the entire rebate payment to be a countervailable benefit because it is available only to exporters. We allocated the total amount of rebate received by each company during the period of review over each company's total exports of the merchandise and weight-averaged the ad valorem benefit by each company's share of exports of the merchandise to the United States. On this basis, we preliminarily determine the net subsidy to be 6.34 percent ad valorem during the period of review. (2) CCS Program The Government of India introduced the CCS program in 1966 with the primary purpose of rebating upon exportation indirect taxes on merchandise. The rebates are paid as a percentage of the f.o.b. invoice price. In the final results of a previous administrative review, we found that the Indian government had satisfactorily demonstrated the requisite linkage between the tax incidence on the merchandise and the CCS payment. Although the Indian government rebates upon export various indirect taxes through the CCS program, the Tariff Act and the Commerce Regulations allow the rebate of only the following: (1) Indirect taxes borne by inputs that are physically incorporated in the exported product (see Annex 1.1 of Part 355 of the Commerce Regulations); and (2) Indirect taxes at the final stage (see Annex 1.2 of Part 355 of the Commerce Regulations). If the payment upon export exceeds the total amount of allowable indirect taxes described above, the Department considers the difference to be an overrebate of indirect taxes and, therefore, a subsidy. Since our last review, we have allowed two additional indirect taxes paid by castings producers. These are the freight equalization levy of Rs. 320 per metric ton, which is levied on pig iron in order to equalize the difference in freight costs among castings producers located in different parts of the country, and the turnover tax of one percent, which is levied on all purchases of raw materials. Because of these additional indirect taxes, the average indirect tax incidence on the merchandise for calendar year 1984 exceeded the 5 percent CCS payment. We preliminarily determine that there is no overrebate of indirect taxes to castings producers and therefore no benefit from this program. (3) Pre-Shipment Export Loans The Reserve Bank of India, through commercial banks, provides pre-shipment or "packing" credit to exporters, allowing them to purchase raw materials and packing materials based on presentation of a confirmed order or letter of credit. In general, the loans are granted for a period of 90 to 180 days, with penalty charges for late interest payments. During the review period, the rate of interest under this program was 12 percent for 90-day loans and 14.5 percent for 135-day loans. However, we verified that one firm received 135-day loans at 14 percent. The maximum comparable commercial interest rate during the 1984-1985 fiscal year was 18 percent, as quoted by the Reserve Bank of India in its bulletin entitled "Report on Trend and Progress of Banking in India" for fiscal year 1984-1985. The interest differential for these loans ranged from 4 to 6 percent during the period of review. We allocated the interest benefit for each company over the total value of the firm's exports of the subject merchandise to all markets. We then weight-averaged the resulting ad valorem benefits by each company's proportion of the value of Indian exports to the United States of this merchandise. On this basis, we preliminarily determine the net subsidy from this program to be 0.62 percent ad valorem. (4) Income Tax Deductions Under section 80HHC of the Finance Act of 1983, the Government of India allowed exporters to deduct 50 percent *35678 of taxes on export sales. During fiscal year 1984, the Indian government modified the program to allow exporters to deduct one percent of taxes paid on export sales during the fiscal year and five percent of taxes paid on the increment of export sales over the previous fiscal year. Because this tax deduction is contingent upon export performance and available only to exporters, we preliminarily determine that it is countervailable. After reviewing the tax claims of the castings exporters during the period of review, we multiplied the income tax deductions claimed by each company by the corporate income tax rate and allocated the resulting benefit over the total value of that firm's exports to all markets during the period of review. We then weight-averaged the resulting ad valorem benefits by each company's proportion of the value of Indian castings exports to the United States. On this basis, we preliminarily determine the net subsidy from this program to be 0.02 percent ad valorem. Under Article 35B of the Finance Act, the Government of India allowed exporters to deduct 133 percent of certain expenses related to market development. Effective April 1, 1983, no income tax benefits were available for expenditures incurred after March 1, 1983. One company claimed an Article 33B income tax deduction in its tax return covering fiscal year 1983 filed during 1984. Because the Indian government allowed deductions for 100 percent for expenses relating to domestic sales, we focused on the remaining 33 percent. We allocated one-third of the deduction over total exports and weight-averaged the resulting ad valorem benefit by the company's share of total Indian exports of the merchandise to the United States. On this basis, we preliminarily determine the net subsidy to be 0.005 percent ad valorem. (5) Other Programs We also examined the following programs, which we preliminarily find exporters of certain iron-metal castings did not use during the review period; A. Market Development Assistance grants; B. Sale of Import Replenishment Licenses; C. Extension of the Free Trade Zones; D. Supply of raw materials at preferential prices; E. Preferential freight rates; and F. Import duty exemptions available to 100 percent export-oriented units. Preliminary Results of Review As a result of the review, we preliminarily determine the net subsidy to be 6.99 percent ad valorem for the period January 1, 1984 through December 31, 1984. The Department intends to instruct the Customs Service to assess countervailing duties of 6.99 percent of the f.o.b. invoice price on any shipments of this merchandise exported on or after January 1, 1984, and on or before December 31, 1984. The Department intends to instruct the Customs Service to collect a cash deposit of estimated countervailing duties, as provided for by section 751(a)(1) of the Tariff Act, of 6.99 percent of the f.o.b. invoice price on shipments of this merchandise entered, or withdrawn from warehouse, for consumption on or after the date of publication of the final results of this administrative review. This deposit requirement shall remain in effect until publication of the final results of the next administrative review. Interested parties may submit written comments on these preliminary results within 30 days of the date of publication of this notice and may request disclosure and/or a hearing within 10 days of the date of publication. Any hearing, if requested, will be held 30 days after the date of publication or the first workday afterward. Any request for an administrative protective order must be made no later than five days after the date of publication. The Department will publish the final results of this administrative review including the results of its analysis of issues raised in any such written comments or at a hearing. This administrative review and notice are in accordance with section 751(a)(1) of the Tariff Act (19 U.S.C. 1675(a)(1)) and § 355.10 of the Commerce Regulations (50 FR 32556; August 13, 1985). Dated: October 2, 1986. Gilbert B. Kaplan, Deputy Assistant Secretary, Import Administration. [FR Doc. 86-22699 Filed 10-6-86; 8:45 am] BILLING CODE 3510-DS-M