"Based on the figures mentioned in the preliminary findings there has been an  all round improvement in the performance of the domestic manufacturer as would be observed from the figures here under:

Particulars	Unit	2007-08	2008-09	2009-10	2010-11 (POI)
Total domestic sales   Indexed	million sq/mtrs	2.26   100	4.02   178	7.61   337	10.94   484
Domestic Production   Indexed	million sq/mtrs	2.47   100	4.73   192	8.84   358	12.46   505
Domestic Market Share	Percentage	52	63	73	71
Capacity   Indexed	million sq/mtrs	6.00   100	18.00   300	18.00   300	18.00   300
Capacity Utilisation	Percentage	41	26	49	69
Capital employed (Indexed)	Rs in lakhs	100	201	322	396
Productivity  Sq/mtrsper Employee (Indexed)	sq/mtrs	100	130	255	310
No. of Employees (Indexed)		100	146	138	158
Export Sales   Indexed	sq/mtrs	0.16   100	0.21   129.81	0.74   451.56	0.83   506.52

The reservations made in the preliminary findings are on account of inventories and profits/return on the capital employed. The inventories are insignificant in absolute terms, as stated here under:

Particulars	2007-08	2008-09	2009-10	2010-11 (POI)
Inventory (Million sq/mtrs)	0.17	0.41	0.78	1.33
Stock in No. of production days	25	32	32	39

It would be observed that with the production of 12.46 million sq/mtrs in 2010-11 (POI) the inventory was 1.33 million sq/mtrs which works out to 39 days production as against inventory of 25 days in 2007-08 and 32 days in 2008-09 and 2009-10.

Furthermore, the company added number of types of products, here again in number of sizes and  thicknesses of the said products. Since the said products are sold to lakhs of dealers all over the country and since the company has made changes in their distribution network to ensure prompt availability of each type of product to each dealer all over the country, the company is required to maintain adequate inventory of the products at its various depots.

Thus it would be obvious that to offer full range of products promptly to all their customers, throughout the country, the company needs to maintain adequate inventory of all types of sizes and thicknesses. Such being the case, the domestic industry has done a phenomenal job in containing the inventory to merely 39 days of production during the POI.

With regard to the profits and return on capital employed, it would be observed that the total demand in the country during the year 2007-08 was only 4.347 million sq/mtrs as detailed herein the figures of 2007-08: Imports from China and Japan - 1.123 million sq/mtrs, imports from other countries - 0.964 million sq/mtrs, sales volume of the domestic manufacturer - 2.260  million sq/mtrs, total demand/consumption - 4.347 million sq/mtrs.

The capacity of the domestic manufacturer was six million sq/mtrs in 2007-08 and the capacity utilisation stood at merely 41%.

It would thus be obvious that TechNova’s total capacity during the year 2007-08 was 138% of the total demand/consumption in the country of 4.347 million sq/mtrs

In a span of one year TechNova put in capital investment to increase their capacity from six million sq/mtrs (in 2007-08) to 18 million sq/mtrs (in 2008-09) in spite of the fact that the total demand/ consumption in the country during 2007-08 was only 4.347 million sq/mtrs

Thus TechNova, in 2008-09 increased their capacity 7.96 times their sales volume of 2.260 sq/mtrs and 4.14 times the total demand/consumption in the country in the year 2007-08.

Further more it made an agreement with Agfa that they would not indulge in any exports of digital plates in countries where Agfa is operating.


TechNova continued to infuse huge capital year after year in spite of their claim of low return on their investments as indexed herein after:

Particulars	2007-08	2008-09	2009-10	2010-11
Capacity (million sq/mtrs)	6	18	18	18
Capital Investment (indexed)	100	201	324	395

The additional capacity was added in 2008-09. However, the company has claimed continued increase in capital employed and depreciation. The increase shown in capital employed is because of the increase claimed in assets  as the company has claimed significant increase in depreciation cost as well as interest cost:

Particulars	2007-08	2008-09	2009-10	2010-11 (POI)
Depreciation (Indexed)	100	271.51	399.51	511.94
Interest (Indexed)	100	377.01	366.94	507.58

Thus the five-fold increase in depreciation as well as interest during the POI is the only cause of injury to the domestic industry, if any.

In any case, in spite of the above decision taken by the domestic industry, the Return on Capital Employed has been more than satisfactory, as can be observed from the figures given herein after:

Particulars	2007-08	2008-09	2009-10	2010-11 (POI)
Return on Capital Employed (Digital plates) – Domestic %	100.00	(1.54)	47.14	40.88

Practically no other product or consumable used in the printing industry is privileged to be treated preferentially. Plate is just like any other consumable used amongst many others (paper, ink, chemicals, blankets, finishing devices, etc.) in the manufacture of a printed product. All these products have innumerable players (domestic and overseas) equally competing to serve the customer. The playing field is level-giving the customer the right to choose, be it quality, price, availability and service among others.

Needless to mention here that God forbid, but if the operations at TechNova stop for any reasons viz. natural calamity or labour unrest, the operations in almost all sectors including the education sector and the newspaper publications throughout the country would come to a complete standstill.


In the review investigation conducted by the Safeguard Directorate relating to aluminium products, TechNova has admitted that the imposition of safeguard duty on Alumimium rolled products from China made TechNova uncompetitive, as they were unable to import their raw material requirements from China and had requested DG-Safeguards to impose corresponding Safeguard Duty on Digital Printing Plates from China PR.

DG – Safeguards (DGSCCE) initiated review probe was terminated vide Notification dated 13.10.2011, after the domestic industry (M/s.Aluminium Association of India and Hindalco) withdrew its application for continued levy of safeguard duty on imports of Aluminium flat rolled products (FRP) and Aluminium Foils.

Safeguard duty termination, automatically addresses the anomaly as claimed by TechNova in their Initiation Notification with demand for anti-dumping duty on Digital Printing Plates.

Since TechNova is not suffering any injury now on account of termination of Safeguard Duty which was earlier imposed on imports of Litho Grade Aluminium from China PR, the investigation on imposition of anti-dumping duty on Digital Plates being imported from China and Japan should also be logically dismissed.


CtCP are nothing but the normal presensitised UV sensitive analogue conventional plates and we are already paying anti dumping duty on the said plates, which was imposed in 2007. In the preliminaryfindings it has been stated that in the case of CtCP plates no EVA coating or mat surface was required. But then TechNova produces several types of PS plates with wide difference in selling prices. Obviously, they are subjected to different coatings.

But that does not change their basic character of being analogue conventional plates. As is the case with coated paper, some are with mat finish and some with glossy finish obviously because of different coating. But all are coated paper under tariff code 4810.

CtCP plates therefore should be excluded from the scope of the product under consideration.


There is a phenomenal market for exports of printed materials. The global export figure of printed materials during the year 2009 was 69.67 USD billion (Rs.3,20,482 crores). –   (Source - Wits UN-Comtrade Database (HS-2002))

The figures of imports and exports of printed materials from India (Source DGCI&S) were  as under in crore rupees:

	2009-10	2010-11
Imports	2464.72	3051.53
Exports	1683.68	1883.35

Export of printed materials from India for the year 2009-10 was only 0.52% of the total global exports in 2009. Exports of printed materials from China amounted to 7.33% of the total global exports in the year 2009.

This is, in spite of the fact that we have the finest printers in the country, who have repeatedly won several International Awards for Excellence in printing including the “Sappi Best Printer of the World” Award.

The inverted duty structure has, as it is, caused serious damage to the printing industry. Presently, the duties are: printed books and manuals - no duty ; printed materials - nil / lower duty, paper and paperboards - 21.93%

If the government decides to impose anti-dumping duty on digital Plates, this will make printing further costly in India, which in turn would further increase the imports of printed materials into India thereby spelling doom for the printing industry in the country.