As a key stakeholder, the ACS was entitled to respond to the initial findings, which cleared supermarkets of many of the criticisms made against them.
ACS chief executive James Lowman said: 'There are still enormous gaps in the information gathered. We are convinced that there is evidence of the major grocery multiples abusing their buying power and manipulating prices at a local level, and the commission must leave no stone unturned in seeking this information.'
The group's submission focuses on two key areas that it feels are missing from the report and that are essential to providing a realistic picture of the sector as it stands.
It believes that the paper lacked recognition of the national wholesale market, compromising independent third parties as well as the big four supermarkets, and that this is critical in analysing the market power in the grocery industry.
Secondly, the ACS claimed the research fell down on analysis of the buying price differentials that lie at the heart of the power imbalance.
Lowman said: 'If the commission does not get to grips with these issues now, it will have failed to grasp the key issues at the centre of this inquiry.'
The ACS's submission was compiled with colleagues from the Federation of Wholesale Distributors, the Scottish Grocers Federation and the Northern Ireland Independent Retail Trade Association, which share the same values when it comes to assessing the strength of national supermarkets.
The ACS argued that additional data gathering is crucial to establishing the size and cause of these differentials.
The association is now under pressure to develop these findings and source evidence before the second full hearing on May 4, before the Competition Commission delivers its final verdict in October.