TP Adjustment - classification of the assessee as a KPO by...

TP Adjustment - classification of the assessee as a KPO by applying safe harbor Rules - classification of the assessee as a KPO by applying safe harbor Rules is totally out of context and does not get any support from the evidences before us. Therefore, the directions of the DRP as well as the observations made by the TPO and thereafter comparing the assessee company with that of high end KPO for benchmarking ALP determination of the comparables is not correct. - AT