Ulquiorra is only 6A with Lanza, and also I don't think Yammy should scale above Secunda Etapa, especially as his feats/showings and portrail are way too underwhelming for this. To use your example, he got nicked by a Getsuga from a 50% Hollowfied Bankai Ichigo. Meanwhile, Ulquiorra completely no-sold a Getsuga from a full power Hollowfied Bankai Ichigo with just his passive Reiatsu alone, the Getsuga couldn't even break through it to touch Ulquiorra.
Add in the fact that Byakuya and Kenpachi were clowning on him to the point of wanting to fight each other more than Yammy, and it starts to not look that good for Yammy being the strongest Espada, SE Ulquirra included.