Import of service

Hi All

Here's a summary of a practical situation I am facing in an audit. Please provide inputs on whether it is an import of service:

-- Holding company is in United Kingdom.

-- Subsidiary company is in India

-- Holding co. shifts some of its employees to the subsidiary co.

-- Subsidiary co. has an employment contract with these employees

-- The salary of these employees is paid by the Holding co. in UK. Subsidiiary co. pays an allowance in India to these employees. However, PF and TDS etc is calculated on the entire salary (paid in UK as well as India)

-- The subsidiary co. reimburses the salary paid by the Holding co. to these employees.

NOW, whether this reimbursement made by subsidiary company is an import of service???

Thanks in Advance