ORDER

PER SHRI LALIET KUMAR, HON’BLE JUDICIAL MEMBER

1. The present appeal is being filed by the assessee for the A.Y. 2020-21 feeling aggrieved by the order passed by the Learned Transfer Pricing Officer [hereinafter in short “Ld.TPO”] on the following grounds: -

1) The order passed by Ld. AO/DRP is bad in law, illegal and non est.

2) Ld. TPO/DRP/A.O. has erred in not accepting the characterization of the assessee as software development provider', The Ld. DRP has erred in observing that the nature of services provided by the assessee are engineering services, computer aided design/engineering. design and modelling etc. and same are in the nature of 'Knowledge Process Outsourcing (KPO)' services. The Ld. DRP has erred in further observing that the adjudication on this ground is unnecessary.

3) Ld TPO/DRP/A.O. has erred in proposing/confirming the addition of Rs. 8,13,50,422/- on account of corporate guarantee fee in respect of guarantee by the assessee in favour of AE

4) The Ld. TPO/DRP/A.O, has erred in proposing/confirming the rate of guarantee fee of 1.90% based on the rates charged by the banks to its customers as against 0.53% charged by the assessee to its AEs.

5) Ld TPO/DRP/A.O, h