Abbey Business Services (India) (P.) Ltd v DCIT [2012] 23 taxmann.com 346 (Bangalore – Trib.) Facts of the case: The assessee-Indian company(Abbey India) incorporated on 22-1-2004 under the Companies Act, 1956 entered into an agreement for secondment of staff with its overseas parent company (Abbey National Plc., UK) on 4-2-2004. The secondment agreement contained inter alia the following clauses 3.2 to 3.6 3.2 Particular Secondments Abbey India and Abbey UK shall complete, sign and date a Secondment Term Sheet in respect of each employee agreed between them to be seconded to Abbey India in accordance with the terms of this Agreement.