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 opportuniti…