The Delhi Income Tax Appellate Tribunal issued a decision dated 5 October 2018 on whether domestic law provisions for the disallowance of deductions may be applied where a tax treaty provides for the deductions. The case concerned Unocal Bharat Ltd. (Unocal), which is a company incorporated in Mauritius and is a wholly owned subsidiary of Unocal Corporation USA. Unocal is engaged in oil and natural gas related activities in India, including the identification of potential business opportunities in the energy sector in India.   In the year concerned, Unocal filed a return claiming a loss of over INR 142 million for...