regarding COP, if such COP exceeds the market value of the input calculated under § 1677b(f)(2). See 19 U.S.C . § 1677b(f) authorize Commerce, in calculating COP and CV, to: (1) disregard a transaction between affiliated parties if, in the case of any element of value that is required to be considered, the amount representing that element does not fairly reflect the amount usually reflected in sales of merchandise under consideration in the market under consideration; and (2) determine the value of the major input on the basis of the information available regarding COP if Commerce has “reasonable grounds to believe or suspect” that an amount represented as the value of the input is less than its COP. See Timken Co. v. United States, 21 CIT 1313, 1327-28, 989 F. Supp. 234, 246 (1997) (<HOLDING>) (citing NSK Ltd. v. United States, 19 CIT
holding that 28 usc  2636c did not modify the filing requirement in 19 usc  1516aa2a holding parties negotiated price of vehicle was evidence of market value as represented holding that 19 usc  1677bf2 and 3 as well as the legislative history of the major input rule support commerces decision to use the highest of transfer price cop or market value to value the major inputs that the producer purchased from the affiliated supplier holding that commerce may disregard transfer price for inputs purchased from related suppliers pursuant to 19 usc  1677be2 1988 the predecessor to 19 usc  1677bf2 if the transfer price or any element of value does not reflect its normal value recognizing potential for fraudulent transfer in foreclosure context if debtor enjoyed significant equity in property but received little or no value from the transfer