Goodluck India Ltd. v. United States, 2020 CIT 57

Commerce initiated an antidumping (AD) investigation of cold‑drawn mechanical tubing from India and selected Goodluck India Limited as a mandatory respondent.
In Commerce's preliminary results Goodluck reported data yielding a de minimis margin, but on the first days of sales and cost verification Goodluck submitted corrected databases that altered its reported results.
Commerce rejected those verification corrections as untimely new factual information, found Goodluck's original reported data unreliable, applied adverse facts available (AFA), and assigned a 33.8% dumping margin in the Final Determination.
Goodluck challenged the Final Determination in CIT; the court held Commerce abused its discretion in rejecting the corrections, treating them as correctible mistakes, and remanded for Commerce to consider Goodluck's corrected submission and explain certain cash‑deposit calculations.
On remand Commerce (under protest) accepted Goodluck's revised databases and recalculated Goodluck's dumping margin as zero percent, removing Goodluck from the AD order.
Defendant‑intervenors urged reconsideration of the court's prior remand; the court found Commerce complied with the remand and sustained the Remand Results.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Commerce abused its discretion by rejecting Goodluck's verification corrections	Corrections were minor, correctible importer mistakes and should have been accepted	Rejection was proper under 19 U.S.C. § 1677m(d)–(e); corrections were untimely new factual information	Court previously held Commerce abused its discretion in rejecting the corrections; on remand Commerce accepted them and the court sustained that outcome
Whether Commerce may apply AFA based on the rejected data	AFA was unwarranted because the record had no gaps and Goodluck did not impede the investigation	AFA was appropriate given Commerce’s finding of unreliable reported data	Court did not reach the substantive AFA question here because Commerce recalculated margin using corrected data on remand (result: 0%)
Whether Commerce complied with the remand order and recalculated margin correctly	Remand compliance required accepting corrected databases and recalculating the margin	Commerce complied by requesting the corrected database, placing it on the remand record, and recalculating (under protest)	Court found Commerce complied with the remand and sustained the Remand Results

NTN Bearing Corp. v. United States, 74 F.3d 1204 (Fed. Cir.) (standard on Commerce discretion to accept or reject information)
Fischer S.A. Comercio v. United States, 700 F. Supp. 2d 1364 (Ct. Int’l Trade) (treatment of ministerial or correctible errors at verification)
Goodluck India Ltd. v. United States, 393 F. Supp. 3d 1352 (Ct. Int’l Trade 2019) (prior CIT decision finding Commerce abused its discretion and remanding)
Beijing Tianhi Indus. Co. v. United States, 106 F. Supp. 3d 1342 (Ct. Int’l Trade) (court reviews remand redeterminations for compliance with remand instructions)