Payment to seconded employees is FTS; Foreign co. is real employer if Indian co. can cancel secondme

IT/ILT: Overseas entity was the real employer of seconded employees when Indian entity had only the right to terminate the secondment without conferring the right to terminate the original employment. Reimbursement of salary of seconded employees to the overseas entities could not be characterized as stewardship and was to be regarded as FTS when they rendered quality control services till the necessary skills were acquired by the resident employee group