TPO segregated international transaction of Professional charges and processed to determine its ALP independently. Tribunal held that  transaction of payment of professional charges was not closely connected with other international transactions. On facts, TPO was justified in segregating international transaction of Professional Charges to be processed independent of other international transactions. Matter remanded.  Since assessee could not produce evidence of availment of services to satisfaction of TPO, TPO held that no services were received and determined Nil ALP.  Detailed e-mail communications between assessee and its AEs abundantly proved that AEs rendered services to assessee which assessee undoubtedly availed. Tribunal held that since no details about comparables of international transaction were either provided by assessee or taken note of by TPO, TPO was directed to determine ALP of international transactions of ‘Professional Charges paid’ afresh in accordance with law. Matter remanded. (AY. 2011-12)