Resolution:
Sending completely empty segments in  X12 transactions is wrong from a standards perspective.
Refer to:  http://www.x12.org/x12org/Subcommittees/X12C/C0300_X12_6.pdf

As per the definition of a segment from section 3.1 Basic Structure in X12.6 Application Control Structure of the X12 004010 specification,

"Each segment is composed of: a unique segment ID; one or more logically related simple data elements or composite data structures, or both, each preceded by a data element separator; and a segment terminator."

The macro #SegmentCount# calculates the empty segments too and puts the wrong value in SE01, which then causes XEngine to fail validation of the outbound EDI data.