OPINION

POGUE, Chief Judge:

This consolidated action seeks review of five determinations by the United States Department of Commerce ("Commerce") in the sixth administrative review of the antidumping duty order on polyethylene retail carrier bags from Thailand.1 Specifically, Plaintiffs Thai Plastic Bags Industries Company, Limited ("TPBI") — a respondent in this review — and two importers of subject merchandise who participated in this review — Master Packaging, Incorporated, and Inteplast Group, Limited (collectively the "Importers") — challenge 1) Commerce's zeroing of, rather than deducting, negative normal-to-export price comparisons in the calculation of respondents' dumping margins; and 2) Commerce's decision, when calculating TPBI's general and administrative expenses, not to deduct income received from an export-conditional government rebate.2 In addition, Plaintiffs Polyethylene Retail Carrier Bag Committee, Hilex Poly Company, LLC, and Superbag Corporation — members of the domestic like product industry who participated in this review (collectively the "Domestic Producers") — challenge 3) Commerce's decision, when calculating TPBI's general and administrative expenses, to include a particular gain from TPBI's sale of assets; 4) Commerce's adjustment of the surrogate financial statements used to construct respondent Landblue (Thailand) Company, Limited ("Landblue")'s normal value to reduce the reported selling expenses in proportion to Landblue's own direct to indirect selling expense ratio for export sales; and 5) Commerce's decision, when calculating Landblue's constructed profit, to use publicly available surrogate financial statements, rather than confidential information from TPBI.3

The court has jurisdiction pursuant to 19 U.S.C. § 1516a(a)(2)(B)(iii) (2006) and 28 U.S.C. § 1581(c) (2006).

As explained below, Commerce's Final Results are sustained with respect to both of TPBI and the Importers' challenges. With regard to the Domestic Producers' challenges, Commerce's calculation of a constructed profit based on publicly available surrogate financial statements is sustained, but Commerce's adjustment of these surrogate financial statements' direct selling expense ratio is remanded. In addition, Commerce's inclusion of TPBI's asset sale gain in TPBI's general and administrative expense calculation is also remanded.

STANDARD OF REVIEW

This court will uphold Commerce's antidumping determinations if they are in accordance with law and supported by substantial evidence. 19 U.S.C. § 1516a(b)(1)(B)(i). Substantial evidence refers to "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." SKF USA, Inc. v. United States, 537 F.3d 1373, 1378 (Fed. Cir.2008) (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938) (defining "substantial evidence")). Moreover, the substantiality of evidence is evaluated "on the record as a whole, including [any evidence that] fairly detracts from its weight." Target Corp. v. United States, 609 F.3d 1352, 1358 (Fed. Cir.2010) (internal quotation marks and citation omitted). The "substantial evidence" standard of review can be roughly translated to mean "is the determination unreasonable?" Nippon Steel Corp. v. United States, 458 F.3d 1345, 1351 (Fed. Cir.2006) (internal quotation and alteration marks, as well as citation, omitted).

DISCUSSION

I. Zeroing

In their request for review of Commerce's decision to zero negative normal-to-export price comparisons in the calculation of respondents' dumping margins, TPBI and the Importers make substantially the same arguments here as TPBI made in the preceding review. Compare TPBI & Importers' Br. at 13-17 with Thai Plastic Bags Indus. v. United States, ___ CIT ___, 895 F.Supp.2d 1337 (CIT 2013) ("Thai Plastic Bags II") (adjudicating TPBI's challenge to Commerce's decision to zero negative price comparisons in the preceding review). Commerce similarly provides the same explanation for its decision as that upheld by this Court in response to TPBI's challenge in that preceding review. Compare I & D Mem. cmt. 6 at 17-18 with Thai Plastic Bags II, ___ CIT at ___, 895 F.Supp.2d at 1341-45. As the record of this review is not materially different from that of the preceding review, Commerce's decision not to aggregate the price differences of TPBI's above-normal value sales with the dumping margins of TPBI's dumped sales (while employing the average-to-transaction comparison method in this review) is affirmed on the grounds stated in Thai Plastic Bags II. See Thai Plastic Bags II, ___ CIT at ___, 895 F.Supp.2d at 1341-45.

II. TPBI's Export-Conditional Government Rebate Revenue

When calculating TPBI's cost of production ("COP") in this administrative review,4 Commerce rejected TPBI's argument that its general and administrative ("G&A") expenses5 should be reduced by the value of a rebate that TPBI received from the Thai government (referred to as the "Blue Corner Rebate" or "BCR revenue"). See I & D Mem. cmt. 1 at 2, 5. TPBI and the Importers claim that this decision was not supported by a reasonable reading of the evidence in the record. TPBI & Importers' Br. at 9-13.

But in its decision, Commerce explained that it did not deduct TPBI's BCR revenue from the COP calculation because the BCR revenue — which TPBI described as rebates received "upon export of TPBI's finished bags"6 — "is related to export sales rather than the COP" and thus "adjusting production costs (or any component of the COP) with the BCR revenue [was] not appropriate." I & D Mem. cmt. 1 at 5. More generally, Commerce reasonably concluded that the COP calculation concerns the respondent's home market,7 whereas export-conditional rebates by definition are not available when the foreign like product is sold domestically. Accordingly, Commerce properly excluded the export-conditional BCR revenue from the COP calculation when determining TPBI's normal value, consistent with Commerce's treatment of Thai BCR rebates in other proceedings.8 Cf. Saha Thai Steel Pipe (Public) Co. v. United States, 635 F.3d 1335, 1338 (Fed.Cir.2011) ("[P]roducers remain subject to [an export-conditional] import duty when they sell the subject merchandise domestically, which increases home market sales prices and thereby increases [normal value].").9

Because the record reasonably supports Commerce's finding that TPBI's BCR revenue was conditioned upon exportation,10 this finding is supported by substantial evidence. See Consol. Edison, 305 U.S. at 229, 59 S.Ct. 206. And because rebates conditional upon exportation are not applicable to merchandise sold in the respondent's home market, Commerce reasonably determined that TPBI's export-conditional BCR revenue was not relevant to TPBI's COP when calculating normal value for TPBI's merchandise. Cf. Saha Thai Steel Pipe, 635 F.3d at 1338. Commerce's decision not to deduct TPBI's BCR revenue from the COP calculation is therefore affirmed.

III. TPBI's Gain From the Sale of Assets

Next, the Domestic Producers challenge Commerce's decision to offset TPBI's G&A expenses11 with the value of a particular gain from the sale of assets that was reflected in TPBI's financial statements. Domestic Producers' Br. at 7-10; see I & D Mem. cmt. 1 at 5-6.12 It is Commerce's practice to include in the G & A expense calculation gains or losses incurred on the routine disposition of fixed assets but to exclude nonrecurring income or losses that are not part of a company's normal production-related business operations.13 Here, Commerce decided to include TPBI's asset sale gain in the G&A expense calculation because Commerce found that this gain was attributable to "the routine disposition of assets." I & D Mem. cmt. 1 at 5-6. As discussed below, however, this decision is not supported by substantial evidence because Commerce did not address record evidence that fairly detracts from its conclusion. See Tudor v. Dep't of Treasury, 639 F.3d 1362, 1366 (Fed.Cir.2011) (quoting Univ. Camera Corp. v. NLRB, 340 U.S. 474, 488, 71 S.Ct. 456, 95 L.Ed. 456 (1951) ("The substantiality of evidence must take into account whatever in the record fairly detracts from its weight.")).

As the Domestic Producers point out, "TPBI provided no information regarding the type of assets sold, and it made no claim or representation that sales of such assets were `routine' or otherwise related to normal production operations." Domestic Producers' Br. at 8; TPBI's Case Br., Admin. R. Con. Doc. 45 [Pub. Doc. 88], at 4 (providing no detail regarding these asset sales beyond the general description of a certain gain "on the sale of assets"). Thus Commerce's conclusion that these sales were routine production-related dispositions was not supported by substantial evidence because it was based on speculation. Cf. Lucent Techs., Inc. v. Gateway, Inc., 580 F.3d 1301, 1327 (Fed.Cir.2009) ("It is well established that speculation does not constitute `substantial evidence.'") (internal quotation marks and citation omitted).

Moreover, Commerce unreasonably concluded, without explanation, that there was "no evidence on the record to suggest that gains on the sales of assets reported in TPBI's audited financial statements are attributable to anything other than the routine disposition of assets." I & D Mem. cmt. 1 at 5-6. On the contrary, the Domestic Producers present a reading of the information contained in TPBI's (confidential) financial statements that fairly detracts from Commerce's conclusion that these asset sales were routine production-related dispositions.14 Commerce's explanation that TPBI's asset sale gain was properly included in the G&A expense calculation because the record contains no evidence to suggest that these sales were unrelated to general manufacturing operations does not adequately address the evidence emphasized by the Domestic Producers. See I & D Mem. cmt. 1 at 5-6.15 Accordingly, Commerce's explanation fails to take into account evidence that fairly detracts from the reasonableness of its conclusion; it is therefore not supported by substantial evidence. See Univ. Camera, 340 U.S. at 488, 71 S.Ct. 456.

Because Commerce's decision to include TPBI's asset sale gain in the G&A expense calculation (based on a finding that this gain was attributable to the routine disposition of production-related assets) was not supported by substantial evidence, it is remanded for further consideration, consistent with this opinion.

IV. Landblue's Constructed Selling Expenses

The Domestic Producers also object to Commerce's selling expense calculation when constructing a normal value for Landblue, another respondent in this review. Domestic Producers' Br. at 10-15.16 Specifically, although the surrogate financial statements used to construct Landblue's selling expenses did not separately report direct and indirect selling expenses, Commerce decided to treat these surrogate statements as though they were comprised of the same ratio of direct to indirect selling expenses as Landblue's actual experience. I & D Mem. cmt. 5 at 14.17

Relying on its "longstanding practice not to make adjustments that may introduce unintended distortions into the data rather than achieving greater accuracy,"18 Commerce concluded that disaggregating and excluding a presumed portion of the surrogate's expenses from Landblue's selling expense calculation would avoid distortion and thereby achieve greater accuracy. See I & D Mem. cmt. 5 at 13-14.19 Commerce decided that it was reasonable to assume that the nature and proportion of the surrogate's direct and indirect selling expenses were similar to Landblue's simply because the surrogate ("Thantawan") was "a Thai producer of similar merchandise, has a similar customer base, and operated with a profit." Id. at 14.

Landblue, however, exported all of its merchandise during the period of review, whereas no evidence suggests that the same is true of Thantawan. See I & D Mem. cmt. 5 at 13-14. Because Landblue exported all of its merchandise, its actual direct selling costs (e.g., freight) are likely to be significantly higher than those of a company selling largely within its home market.20 And as "Thantawan's total selling expenses do not provide details on whether the expenses are direct or indirect in nature," I & D Mem. cmt. 5 at 14, Commerce merely presumed — based solely on the possibility that some (unknown) portion of Thantawan's selling expenses may have been comprised of direct expenses — that introducing Landblue's (export-based) direct expense ratio into the calculation of constructed value was more likely to result in greater accuracy than further distortion. See id.21

Because unfounded assumptions are not evidence, Commerce's decision that adjusting Thantawan's selling expenses to reflect Landblue's own direct expense ratio would avoid distortion and achieve greater accuracy is not supported by a reasonable reading of the evidence in the record. This matter is therefore remanded for further consideration, consistent with this opinion.

V. Landblue's Constructed Profit

Finally, the Domestic Producers claim that Commerce improperly constructed Landblue's profit22 from publicly available Thai surrogate information, rather than using TPBI's confidential information. See Domestic Producers' Br. at 15-16 (emphasizing that, unlike TPBI's financial statements, the surrogate financial statements used to construct Landblue's profit did not disaggregate profits attributable specifically to sales of foreign like product in Thailand). But because TPBI was the sole other respondent selected for individual examination in this review,23 Commerce could not have relied on TPBI's financial statements without revealing TPBI's business-proprietary information in contravention of the administrative protective order. Cf. Polyethylene Retail Carrier Bags from Thailand, Issues & Decision Mem., A-549-821, Investigation (June 18, 2004) ("Bags from Thailand Investigation") cmt. 4 at 21 ("[B]ecause there is only one other respondent in this case, [Commerce] could not calculate ... profit based on [actual amounts realized by the other respondent] because [doing so] would reveal the business-proprietary information of the other respondent...."). Accordingly, Commerce reasonably determined that relying on TPBI's profit information was not an available alternative.24 See Geum Poong Corp. v. United States, 25 CIT 1089, 1092, 163 F.Supp.2d 669, 674 (2001) (holding that Commerce properly determined that an alternative was unavailable where it would impermissibly reveal a respondent's proprietary profit ratio). This determination is therefore affirmed. See id.

CONCLUSION

For all of the foregoing reasons, Commerce's Final Results are sustained except with regard to 1) Commerce's decision to include TPBI's asset sale gain in the calculation of TPBI's G & A expenses; and 2) Commerce's adjustment of the surrogate financial statements used to construct Landblue's selling expenses to reflect Landblue's own direct to indirect selling expense ratio. As explained above, these issues are remanded for further consideration, consistent with this opinion. Commerce shall have until May 20, 2013, to complete and file its remand results. Plaintiffs and Defendant-Intervenors shall have until June 3, 2013, to file comments. The parties shall have until June 10, 2013, to file any reply.

It is SO ORDERED.