Assessee-company was engaged in manufacturing of commercial truck tyres, road tyres and rear farm tyres.  Assessee entered into a Service Agreement with its AE for receipt of regional services. Assessee adopted CUP method to demonstrate that international transaction of payment of Regional Service Charges (RSC) was at Arm’s Length Price (ALP).  TPO determined Nil ALP for five regional services on ground that there was no evidence of receipt of services by assessee or assessee did not receive any benefit from such services.  Assessee produced certain e-mails before TPO to demonstrate receipt of services. However, TPO did not infer factum of receipt of services from said e-mails by holding that those e-mails were either general or did not refer to receipt of services by assessee. On appeal the  Tribunal held that   text of said e-mails gave detailed account of nature of regional services furnished to assessee, there remained not even an iota of doubt that assessee did receive such services from its AE. Therefore, it was not justified on part of TPO to hold that said e-mails were general e-mails not evidencing any provision of services to assessee.  (AY. 2014-15, 2015-16)