Roundup of Recent Developments in Indian Competition Law

The Indian competition law regime has undergone substantial changes over the past few years and is constantly evolving both in terms of regulations as well as the Competition Commission of India’s (“CCI”) decisional practice. This note covers key developments in the Indian competition law over the past year.¹

Merger Control: The CCI reviewed about 135 merger filings in the Previous Year, of which: (i) 113 transactions were finally approved by the CCI, (ii) 18 transactions were ‘deemed approved’ under the ‘green channel’ route,² (iii) 124 transactions were notified to the CCI in Form I (short form filing), (iv) 11 transactions were notified in Form II (long form filing), (v) at least ten transactions were notified under the recently introduced ‘deal value thresholds,’³ (vi) two notices were approved with modifications,⁴ (vii) one transaction was treated as exempt from notification requirement.⁵ Some of the key merger control orders in this period are summarized at Section I below.
Enforcement: The CCI passed a total of 49 orders in the Previous Year, of which, the CCI: (i) directed investigations in 16 cases, (ii) imposed penalties in six cases, (iii) closed 24 cases, and (iv) passed one settlement order.⁶
Other Key Developments: The CCI issued an updated version of its ‘Frequently Asked Questions on Combinations’ (“FAQs”), providing much needed certainty on several issues. The Previous Year was also marked by the CCI’s engagement with emerging issues through its Market Study on Artificial Intelligence and Competition (accompanied by a self-audit framework for businesses developing or using artificial intelligence (“AI”)). Further, the Ministry of Corporate Affairs indicated its intention to conduct market studies to provide a solid foundation for the Draft Digital Competition Bill (“DCB”).

I. Key Merger Control Cases

Avoiding a literal approach:⁷ In a transaction involving an acquisition of 1.64% of the shares of an enterprise, the acquirer notified the transaction to the CCI purely as a matter of technical compliance, owing to the absence of any specific exemption in relation to ‘intra-group acquisitions’ (the seller entities and the acquirer were under the sole control of the same group).
While an exemption applicable to acquisitions of less than 25% of the shares of an enterprise was technically applicable to only “acquisition of additional shares or voting rights of an enterprise by the acquirer or its group entities” (“Rule 3”), based on a ‘literal reading’, such exemption was available only in instances involving an acquisition of additional shareholding, and not otherwise.

The CCI observed that a literal interpretation of the Competition (Criteria of Exemption of Combinations) Rules, 2024 (“Exemption Rules”) would lead to an apparent fallacy in certain situations, and would require otherwise non-notifiable transactions to be notified to the CCI.

Accordingly, the CCI observed that a literal interpretation of Rule 3 in terms of acquisition of ‘additional shares’ being eligible for exemption and absence of ‘incremental shareholding’ (which is at a lower pedestal) not being eligible for exemption, was inconsistent with the scheme and spirit of the Competition Act, 2002, as amended (“Competition Act”) and the Exemption Rules. The CCI confirmed the applicability of Rule 3 for the proposed acquisition and stated that the transaction did not require notification.
The merger control regime in India is mandatory and suspensory in nature, despite the existence of any ‘critical or extenuating circumstances’:⁸ In a transaction where a debenture trustee was constrained to issue a notice for conversion of debentures to equity shares (due to an event of default by the target enterprise under the debenture trust deed), triggering an acquisition, the acquirer requested the CCI to take a purposive and holistic interpretation of the Competition Act for not having sought the CCI’s prior approval for such acquisition.
The CCI observed that the merger control regime in India is mandatory and suspensory in nature, transactions (which breach certain prescribed thresholds) are notifiable unless they can avail of any exemptions, and cannot be consummated, neither entirely nor in part, without the CCI’s prior approval.

Therefore, while the CCI found that the acquirer failed to give notice to the CCI prior to the allotment of shares, considering certain mitigating circumstances (i.e., (i) absence of any special rights acquired pursuant to the acquisition, (ii) the acquisition was critical considering that it was safeguarding the future of almost four lakh students and more than 10,000 employees, which were put in jeopardy due to the event of default by the target enterprise, (iii) the acquisition did not result in any appreciable adverse effect on competition in any markets in India, and (iv) the acquirer had acted in a bona fide manner), the CCI imposed a penalty of only INR two million on the acquirer.⁹
Approval of transaction subject to commitments offered by the parties to maintain separate business operations:¹⁰ The proposed transaction involved Bharat Forge Limited’s (“BFL”) acquisition of 100% of the equity shares of AAM India Manufacturing Corporation Private Limited (“Target”).
The CCI’s substantive competition concerns arose from the parties’ horizontal overlaps in the ‘market for supply of axles for commercial vehicles in India,’ particularly in the medium and heavy commercial vehicle axle segment, where the parties had a combined market share of 60-65%.

To remedy CCI’s concerns, and to ensure that BFL’s affiliate joint ventures and the Target continue to compete pursuant to the transaction, BFL offered behavioral commitments to maintain ‘separate business operations’ of BFL’s affiliate joint ventures and the Target for a period of seven years.

Such commitments included ring-fencing measures, prohibition on common board members/ key managerial persons/ employees, requirements for distinct brand identities, and ensuring independent sales/ marketing functions and independent participation in request for proposal/ quotation, which the CCI accepted.
Approving a transaction in the pharmaceutical sector with a mix of structural and behavioral remedies:¹¹ In a transaction involving an acquisition of shares of J. B. Chemicals & Pharmaceuticals Limited by Torrent Pharmaceuticals Limited, and their subsequent amalgamation as a going concern, the CCI observed as follows:
1. Markets for Lactobacillus Acidophilus finished dosage forms (“FDF”) and Nifedipine FDF: The combined market share of the parties pursuant to the transaction was in the range of 95-100%, which would be indicative of the proposed transaction being likely to result in a significant change in concentration levels in the market and eliminate the only plausible source of competitive constraints on the parties.
2. Market for Azelnidipine FDF: While the combined market share of the parties pursuant to the transaction was in the range of 45-50%, the CCI observed that the proposed transaction was likely to result in significant change in concentration levels in this market (the target’s drug was 13% cheaper as compared to the acquirer’s drug, and given the difference in prices, the proposed transaction was likely to incentivize elimination of the cheaper drug).
The CCI approved the transaction after considering the modifications proposed by the parties, which consisted of a mix of structural and behavioral remedies, including the following:
1. Lactobacillus Acidophilus Remedy: The CCI observed that the acquirer would license its Vizylac brand (comprising products containing Lactobacillus Acidophilus as a single strain FDF) to an independent entity for a period of five years from the date of such license, for a lump sum license fee (as agreed between the acquirer and licensee).
2. Nifedipine Remedy: The CCI observed that the acquirer would divest (or procure the divestiture of) all products containing Nifedipine FDF which are currently marketed and supplied under the Calcigard brand, to a purchaser, on terms of sale approved by the CCI.
3. Azelnidipine Remedy: The CCI observed that the acquirer will continue the marketing and sale of the target’s Azovas brand, and the acquirer will cap any price increases for Azovas at no more than 5% per annum for a period of three years.
Review of new age markets:¹² The CCI approved a transaction involving Coinbase Global Inc.’s acquisition of additional shareholding in DCX Global Limited (“DCX”), pursuant to which DCX would acquire 100% of the shares of Neblio Technologies Private Limited (“Neblio”).
Based on the activities of the parties, the CCI noted that the parties delineated the broad relevant market as the ‘market for exchanges offering crypto currency services in India’ (“Crypto-Exchange Market”), and since both Coinbase and Neblio operated centralized crypto exchanges, the narrow relevant market was identified as the ‘market for exchanges offering crypto currency services through Centralised Crypto Exchanges (CEX) in India’ (“CEX Market”).

Considering (i) the market shares of the parties, (ii) incremental market shares being minimal (as a result of this transaction), and (iii) that each of the Crypto-Exchange Market, and the CEX Market were characterized by the presence of other players, the CCI approved this transaction.
Transactions involving a change from ‘joint control’ to ‘sole control’ will need to be considered carefully:¹³ In a transaction involving an acquisition of 100% of the shares of the target enterprise by an acquirer (who already held 70% of the shares), the CCI noted that the sole seller (which held 30% of the shares of the target enterprise) exercised ‘negative control’ in terms of shareholding and veto rights on reserved matters, prior to the proposed transaction.
The CCI denied the benefit of erstwhile Item 2 of Schedule I of the Competition Commission of India (Procedure in regard to the transaction of business relating to combinations) Regulations, 2011 (“Erstwhile Combination Regulations”) to this transaction (Item 2 was not applicable where a “transaction results in transfer from joint control to sole control”), observing that the proposed transaction resulted in an explicit ‘change in control’ of the target enterprise from ‘joint control’ to ‘sole control’ – given the sole seller’s exercise of negative control (in terms of its shareholding and veto rights on reserved matters), and imposed a penalty of INR five million on the acquirer for non-notification of the transaction to the CCI.
CCI not assessing transactions without definitive documents being executed: The CCI reaffirmed its position that it confines its assessment to transactions that are binding and sufficiently certain at the time of notification, and declined to extend its review to contingent or prospective mergers and acquisitions:
1. In Sumitomo Mitsui Banking Corporation,¹⁵ the CCI observed that binding transaction documents in relation to an additional share acquisition had not yet been executed. Accordingly, the CCI observed that the acquirer may evaluate the notifiability of such additional acquisition, if any, at the time of execution of requisite binding transaction documents; and
2. In Curefit Healthcare/ Fitness First Luxembourg (“FF Lux”),¹⁶ where FF Lux disclosed that it ‘may’ acquire certain shareholding in Curefit Healthcare from certain sellers, the CCI noted that such transactions remained uncertain, and observed that they did not form part of the CCI’s present assessment.
Temporal boundary on the scope of CCI’s approval:¹⁷ In a multi-step transaction notified to the CCI, one of the steps involved an acquisition of shares of a target enterprise pursuant to a call or put option, exercisable within a period of eight years, ‘or an additional period agreed’ between the shareholders of the acquirer and the target. The CCI approved the exercise of such options only within the eight-year period – thereby imposing a temporal boundary on the scope of its approval.

II. Key Enforcement Cases

CCI issued its first ‘settlement’ order in the Google Android TV case:¹⁸ In a complaint filed in the year 2020 against Google LLC, Google India Private Limited (collectively “Google”), Xiaomi Technology India Private Limited, and TCL India Holding Private Limited, it was alleged that Google abused its dominant position by enforcing restrictive agreements on smart TV manufacturers, by (i) ensuring compulsory bundling of the Play Store with Android TV Operating System (“OS”) and (ii) preventing the use or creation of rival forked OS versions through its agreements with the smart TV manufacturers. It was alleged that such practices blocked market access, curbed competition, and placed unrelated obligations on the smart TV manufacturers, stifled innovation and constituted an abuse of dominant position by Google.
The Director General’s (“DG”) investigation found Google’s Android Smart TV OS to be dominant in the ‘market for licensable Smart TV device operating system in India’ and Google Play Store to be dominant in the ‘market for App Store for Android Smart TV OS in India.’

On allegations of abuse of dominant position by Google, the DG found that Google’s agreements (i.e., Television App Distribution Agreement (“TADA”) and Android Compatibility Commitments (“ACC”)) (i) imposed unfair terms on smart TV manufacturers by requiring the pre-installation of Google’s full app bundle of Google TV services/ Google applications, and (ii) prevented smart TV manufacturers from developing or using Android forks, and hindered innovation.

Subsequently, Google filed a settlement application with the CCI.¹⁹ The CCI invited objections and suggestions on Google’s settlement proposal from 45 concerned parties, considered Google’s proposal and observed that: (i) Google’s proposed ‘New India Agreement’ would provide a standalone license for the Play Store and Play Services for Android smart TVs in India, thereby removing the requirement to bundle these services or impose default placement conditions, and (ii) Google would allow its Android TV partners to use the open source Android OS without installing Google apps or adhering to the ACC, and to use other competing OS while developing smart TVs.²⁰

Accepting Google’s settlement proposal, the CCI determined the settlement amount as INR 202.4 million (applying a settlement discount of 15%).
The Supreme Court of India (“Supreme Court”) considered principles of “unfair or discriminatory” conduct, margin squeeze, requirement of effects-based harm analysis in abuse of dominant position cases, and importance of cross-examination:²¹ The Supreme Court upheld the erstwhile Competition Appellate Tribunal’s decision setting aside the penalty of INR 56.6 million imposed by the CCI on Schott Glass India Private Limited (“Schott India”) by, inter alia, observing as follows:
1. For conduct to be “unfair or discriminatory,” it should be established that transactions which were materially equivalent were accorded materially different treatment: The Supreme Court observed that Schott India’s target-discount scheme was neither discriminatory nor exclusionary, given that it was not established that transactions which were materially equivalent were accorded materially different treatment, and it is only unequal pricing for equal transactions that contravenes Section 4(2)(a) of the Competition Act.²²
  On facts, the Supreme Court found that Schott India had circulated a single rebate ladder (of 2%, 5%, 8% and 12%) which was applicable to all customers, and every customer who reached a certain slab, whether by one purchase order or by several, received the corresponding rebate. Hence, Schott India’s target-discount scheme was neither discriminatory nor exclusionary.
2. Clear, demonstrable evidence is necessary to support allegations of margin squeeze: Margin squeeze is an anti-competitive concern where a vertically integrated firm fixes the wholesale input price high, and its own downstream price low, such that downstream rivals, though equally efficient, cannot create a viable profit margin.
  On facts, Schott India had a Long-Term Tubing Supply Agreement (“LTTSA”) with Schott Kaisha Private Limited (“Schott Kaisha” a Schott group company’s joint venture with Kaisha Manufacturers, which was engaged in the downstream market²³) where Schott Kaisha undertook that it would source at least 80% of its aggregate requirement of neutral tubing from Schott India for three financial years. In consideration, Schott Kaisha received certain preferential contractual terms from Schott India.
  
  The Supreme Court, inter alia, found that the LTTSA was not anti-competitive given that (i) there was no downstream participation by Schott India – the downstream entity (Schott Kaisha) was a separate company, (ii) evidence suggested that an equally efficient converter could, and did, operate profitably notwithstanding the LTTSA, (iii) during the entire period of the LTTSA, every independent converter recorded positive EBITDA, (iv) seven of the nine converters improved both tonnage and margin year-on-year, and (v) no purchaser other than Schott Kaisha sought or was denied comparable terms.
3. An effects-based harm analysis is mandatory for establishing abuse of dominant position – actual or likely anti-competitive effects must be established by the CCI.
4. Where material findings of the DG’s investigation report depend on the statements of witnesses, failure to offer or grant an opportunity to cross-examine such witnesses would amount to a violation of the principles of natural justice and vitiate the investigation.
The National Company Law Appellate Tribunal’s (“NCLAT”) partial modification of the CCI’s order in the WhatsApp case:²⁴ In November 2024, the CCI held that Meta Platforms, Inc. (“Meta”) through WhatsApp LLC (“WhatsApp”) (Meta is the parent company of WhatsApp) abused its dominant position in the market for over-the-top (“OTT”) messaging apps by introducing an updated privacy policy in 2021 (“2021 Policy”), which allegedly made it mandatory for the users to accept certain terms and conditions in order to retain their WhatsApp account, and allowed WhatsApp to share personalized user information with other Meta companies.
The CCI’s order held as follows:
1. the 2021 Policy imposed unfair conditions on users;
2. the sharing of WhatsApp users’ data between Meta companies for purposes other than providing WhatsApp services created an entry barrier for the rivals of Meta, resulting in denial of market access for competitors in the ‘market for online display advertising;’ and
3. Meta leveraged its dominant position in the ‘market for OTT messaging apps through smartphones in India’ to protect its position in the ‘market for online display advertising.’
Consequently, the CCI imposed a penalty of INR 2.13 billion on Meta, imposed a ban of five years on WhatsApp on sharing user data collected on its platform with other Meta companies or products for advertising purposes, and directed Meta and WhatsApp to implement certain directions in relation to the sharing of user data between WhatsApp and Meta companies (such directions included giving consumers a choice to manage their data including by way of an opt-out option) (collectively, “CCI’s Directions”).

On appeal, the NCLAT upheld the CCI’s findings on points (a) and (b) above, but rejected the CCI’s findings on point (c) above by observing that Meta was only a leading player and not dominant in the ‘market for online display advertising,’ therefore no question of abuse of dominant position, or leveraging of dominant position could arise.

The NCLAT also set aside the five year ban on WhatsApp, given that (i) the rationale for a five year ban on WhatsApp was missing in the CCI’s order, (ii) based on the CCI’s order, once a user has been provided with an option to freely decide to opt-in or opt-out, the five year ban becomes redundant. However, it was clarified that the other CCI’s Directions with respect to providing an explanation to users and giving consumers a choice to manage their data, including by way of an opt-out option, will apply (for both advertising and non-advertising purposes).

In appeals before the Supreme Court (by the CCI, Meta and WhatsApp), Meta and WhatsApp submitted that they have decided to implement and comply with the directions issued by NCLAT, without prejudice to the issues raised by them before the Supreme Court in their appeals. These appeals are currently pending before the Supreme Court.²⁵
Supreme Court held that CCI approval for resolution plans is required to be taken prior to the resolution plan being considered by the Committee of Creditors:²⁶ (see, S&R’s critical analysis of the Supreme Court’s judgement here).
Delhi High Court holds that the issuance of a demand notice is a mandatory pre-condition before any ‘interest’ on penalties can be imposed by the CCI:²⁷ On August 30, 2018, the CCI imposed a penalty of INR 96.4 million on Geep Industries (India) Private Limited (“Geep”, and certain other parties) for anti-competitive conduct in the dry-cell batteries market in India, and directed the penalty to be deposited within 60 days of receipt of the order. The CCI’s order was received by Geep on September 10, 2018.
Subsequently, the NCLAT on March 31, 2023, upheld the CCI’s findings of contravention against Geep but, inter alia, reduced the penalty imposed to INR 24.1 million.

The CCI issued demand notices in May 2023 directing Geep to deposit the penalty amounts within 30 days, along with interest at the rate of 1.5% per month calculated from December 10, 2018 (i.e., the 91^st day from the receipt of the CCI’s order on September 10, 2018).

Geep filed a petition before the Delhi High Court which held that based on applicable regulations,²⁸ the issuance of a demand notice is a ‘mandatory pre-condition’ before any ‘interest’ on penalties can be imposed by the CCI. Accordingly, the Delhi High Court set aside the CCI’s demand notice to the extent it levied ‘interest’ on the delayed payment of the CCI’s penalty amount by Geep.
Bombay High Court held that there is no jurisdictional embargo on the CCI to entertain a subsequent complaint if found to be distinct/ different from an earlier complaint:²⁹ Following a complaint by Grasim Industries Limited (“Grasim”), the CCI in July 2025 initiated an investigation into allegations of abuse of dominant position by Asian Paints Limited (“Asian Paints”) in the ‘market for the manufacture and sale of decorative paints in the organized sector in India’.³⁰
In an earlier complaint in 2022, the CCI found no evidence of abuse of dominant position by Asian Paints despite a thorough investigation.³¹

Asian Paints, inter alia, argued before the Bombay High Court that the CCI was jurisdictionally barred³² from entertaining Grasim’s complaint on the same or substantially the same facts and issues, once the same allegations were already decided by the CCI in its previous order.

The Bombay High Court rejected Asian Paints’ plea for the reason that (i) the relevant provisions of the Competition Act invoked by Grasim were not the same as invoked in the earlier complaint, (ii) the primary reason for dismissal of the earlier complaint was that there was no adequate material supporting the earlier complaint, and (iii) there is no jurisdictional embargo on the CCI to entertain a subsequent complaint, if it is found to be distinct/ different from the earlier complaint.
CCI closed the investigation against BookMyShow (“BMS”):³³ The CCI’s closure order observed that BMS was dominant in the ‘market for online intermediation services for booking of movie tickets in India,’ however, such dominant position was tempered by the dynamic nature of the market, the presence of other players (such as Paytm and Justickets), and the reciprocal commercial dependence between BMS and cinema operators.
On the specific allegations made by the informant, the CCI concluded that: (i) the reservation of a minimum number of seats for BMS in single-screen cinema agreements was operationally justified to prevent overlapping bookings (particularly in tier-2 and tier-3 cities lacking real-time integration), (ii) exclusive data ownership clauses imposed by BMS were neither unfair nor discriminatory, since BMS shared customer data with cinemas on request and the differentiation between single-screen cinemas and multiplexes reflected material differences in infrastructure and capacity; (iii) differences in convenience fee revenue-sharing (up to 55% with single screens and up to 77% with multiplexes other than PVR) were based on multiple commercial factors and the CCI declined to act as a price regulator; and (iv) exclusivity clauses coupled with lock-in periods were operationally justified, since (a) the lock-in period was directly linked to the amount of advance paid to the cinemas and provided reasonable opportunity for BMS to recoup its financial outlay and not be rendered remediless in the event of premature exit by the cinemas, and (b) such clauses generally promote business stability and efficiency.
CCI imposed penalty on Intel Corporation (“Intel”) for parallel warranty service policy:³⁴ The CCI held that Intel’s warranty service policy for India, where Intel would entertain warranty requests for its Boxed Microprocessors (“BMPs”) in India only when they are purchased from an authorized Indian located distributor of Intel, was an abuse of Intel’s dominant position.
The CCI order noted that Intel was not acknowledging warranty requests on its BMPs that were purchased from its authorized distributors in the rest of the world and instead redirected them to the country of purchase to avail the warranty. The CCI observed that (i) Intel’s warranty policy in India was discriminatory in comparison with Intel’s warranty policies in China, Australia and rest of the world, and (ii) the warranty policy restricts the choice of consumers and parallel importers.
CCI initiated investigation against InterGlobe Aviation Limited (“Indigo”) on allegations of abuse of dominant position,³⁵ and closed another complaint against Indigo and Air India Limited (“Air India”) on allegations of collective dominance:³⁶ The CCI initiated an investigation against Indigo observing that in December 2025, widespread inconvenience was caused to travelers due to sudden and massive cancellation of flights with little or no alternatives available, the passengers were left stranded with severely limited options, and the flight fares escalated sharply. Such conduct was prima facie viewed by the CCI as unfair and restricting the provision of services by a dominant entity.³⁷
The CCI order also relied upon responses from the Directorate General of Civil Aviation in prima facie rejecting Indigo’s arguments that the CCI lacked jurisdiction to adjudicate sector specific issues, and concluding that Indigo was dominant in the ‘market for domestic air passenger transport services in India.’

Approximately a month later in March 2026, the CCI closed a complaint against Indigo and Air India rejecting allegations of collective dominance, and anti-competitive activities in relation to the determination of airlines’ cancellation charges by observing that: (i) collective dominance is not recognized under the Competition Act, (ii) the airlines have a system in place for refund of tickets which the customers are informed of well in advance, and such terms are applied equally to all consumers and not in a discriminatory, unfair or exclusionary manner, and (iii) dissatisfaction with a contractual term or desire for more favorable terms and conditions does not constitute violation of the Competition Act.
The Supreme Court, Delhi High Court and the NCLAT held that the CCI lacks the power to examine the allegations under the Patents Act, 1970 – which will prevail over the Competition Act.³⁸
The Kerala High Court held that the CCI and Telecom Regulatory Authority of India have concurrent jurisdiction over competition-related issues in the broadcasting sector.³⁹
Antitrust cases involving Google: In addition to the order involving a settlement order being passed in relation to Google Android TV investigation (see Section II.1 above), the Previous Year also saw the following antitrust cases involving Google:
1. Google’s commitment application in the Real Money Games apps case:⁴⁰ Following the CCI’s investigation initiation order against Google in November 2024, Google filed a commitment application with the CCI.⁴¹ The CCI issued a public notice inviting comments on Google’s proposed commitments. Google’s proposed commitments addressed the concerns identified in the CCI’s investigation initiation order regarding exclusion of Real Money Games apps from Google Play Store and discriminatory advertising policies.
2. The CCI clubbed a fresh complaint against Google in ‘AdTech Stack’ business with the Publishers Case:⁴² Noting that the allegations raised against Google’s AdTech Stack intermediation business⁴³ are already subject to an ongoing investigation (“Publishers Case”)⁴⁴, the CCI clubbed the fresh complaint with the Publishers Case and directed the DG to investigate the alleged practices of Google in the market for online display advertising services and/ or AdTech intermediation services, and submit a consolidated investigation report in the matters.
3. Closure of a fresh complaint in the online search advertising market:⁴⁵ A fresh complaint filed by Alliance of Digital India Foundation against Google alleging unfair and discriminatory conditions imposed by Google upon advertisers as part of its Google Ads Policies was closed by the CCI, given that such allegations have already been examined in substance and laid to rest by the CCI in previous decisions.⁴⁶
4. The CCI’s closure order in allegations concerning suspension of app developer account, and unfair clauses under Google Play Developer Distribution Agreement (“DDA”):⁴⁷ The CCI found Google’s explanation of the suspension of app developer accounts, Google’s ‘relation ban policy’ and appeals process to be reasonable, and the DDA to be a standard industry practice and a standard form contract entered into by all developers wanting to list their apps on Google Play Store.
5. The CCI’s closure order in allegations concerning grievance of a developer involved in violation of Google Play policies:⁴⁸ The CCI found that Google followed its declared policy in terms of terminating accounts which were hosting applications exhibiting suspicious activity, and finally re-instated the account after its review process.
The CCI’s investigation relating to fragrance and fragrance ingredients manufacturers:⁴⁹ In August 2025, the CCI initiated an investigation against certain fragrance and fragrance ingredients manufacturers. A challenge to the CCI’s investigation initiation order by one of the parties being investigated by the CCI on grounds of expiry of the limitation period within which investigation may be initiated by the CCI, was rejected by the Delhi High Court.

III. Other Key Developments

CCI issued Updated FAQs on Merger Control: Please see S&R’s update on the FAQs here.
Market Study on AI and Competition in India:⁵⁰ The CCI’s market study on AI noted that the deployment of AI tools can both be pro-competitive and potentially competition-distorting.
The study (i) highlighted potential competition issues related to the use of AI, such as AI-facilitated collusion (including through use of pricing algorithms), and potentially problematic conduct of dominant entities in AI (such as self-preferencing, tying and bundling, predatory pricing), (ii) analyzed certain effects of the use of AI on markets, including targeted or personalized price discrimination, reduced transparency, reduced consumer choice, and opaque “black-box” decision-making that could make anti-competitive conduct harder to detect, and (iii) provided an indicative self-audit framework for businesses that develop, deploy, or use AI systems, recommending that such audits be conducted to ensure compliance with the Competition Act.
The Ministry of Corporate Affairs issued an RFP to engage an agency/ institution to undertake a market study on thresholds for big tech companies and core digital services:⁵¹ In July 2025, the Ministry of Corporate Affairs clarified that the DCB, which contained provisions addressing anti-competitive practices including self-preferencing and anti-steering for enterprises designated as Systemically Significant Digital Enterprises⁵² (“SSDE”) under the DCB, “based on the suggestions/comments/inputs received, it is felt that an evidence-based foundation through market studies is required to consider all relevant aspects for ex-ante regulation considering it is in nascent implementational stages globally.”⁵³
In November 2025, the Ministry of Corporate Affairs issued a Request for Proposal to engage an agency/ institution to undertake a market study on “Qualitative and Quantitative thresholds for Big Tech Companies and Core Digital Services.”⁵⁴
CCI published Diagnostics Tool for Public Procurement Officers:⁵⁵ In May 2025, the CCI issued a practical toolkit for public procurement officers to embed competition safeguards and detect bid rigging in tenders. The toolkit also provides ‘recommended best practices’ that may be followed by procurement officers at various stages of procurement process.
Dawn Raids:⁵⁶ Based on news reports, it appears that the CCI conducted ‘dawn raids’ at the premises of (i) six paper mills over allegations of price fixing; and (ii) certain steel pipe manufacturers in relation to allegations of bid rigging.

¹ In the financial year ended March 31, 2026 (the “Previous Year”).
² A ‘green channel’ notification is a Form I which is filed with the CCI when there are no horizontal, vertical or complementary overlaps between the activities of the parties.
³ The ‘deal value thresholds’ were introduced pursuant to the 2024 amendments to the Indian merger control regime. Please see S&R’s update on the 2024 amendments here.
⁴ See the CCI’s orders in (i) Bharat Forge Limited, dated April 22, 2025 in C-2024/10/1197; and (ii) Torrent Pharmaceuticals Limited, dated October 21, 2025 in C-2025/07/1299.
⁵ See the CCI’s order in Kedaara II Continuation Fund, dated September 8, 2025 in C-2025/08/1311.
⁶ In the years ended March 31, 2025 and March 31, 2024, the CCI passed a total of 59 and 43 orders, respectively. Further, in the financial year ended March 31, 2025, the CCI directed investigations in 12 cases, imposed penalties in four cases, and closed 39 matters (see the CCI’s Annual Report for the financial year ended March 31, 2025 (available here, at pages 1, 15 and 33).
⁷ See the CCI’s order in Kedaara II Continuation Fund, dated September 8, 2025 in C-2025/08/1311.
⁸ See the CCI’s order in Manipal Health Systems Private Limited & Anr., dated July 31, 2025 in C-2024/05/1142.
⁹ Section 43A of the Competition Act (prior to the 2024 amendments) stated as follows: “Power to impose penalty for non-furnishing of information on combinations 43A. If any person or enterprise who fails to give notice to the Commission under sub- section (2) of section 6, the Commission shall impose on such person or enterprise a penalty which may extend to one percent, of the total turnover or the assets, whichever is higher, of such a combination.”
¹⁰ See the CCI’s order in Bharat Forge Limited, dated April 22, 2025 in C-2024/10/1197.
¹¹ See the CCI’s order in Torrent Pharmaceuticals Limited, dated October 21, 2025 in C-2025/07/1299.
¹² See the CCI’s order in Coinbase Global Inc., dated December 16, 2025 in C-2025/10/1342.
¹³ See the CCI’s order in Allcargo Logistics Limited, dated January 8, 2026.
¹⁴ Item 2, Schedule I of the Erstwhile Combination Regulations stated as follows: “An acquisition of shares or voting rights, referred to in sub-clause (i) or sub-clause (ii) of clause (a) of section 5 of the Act, where the acquirer, prior to acquisition, has fifty percent (50%) or more shares or voting rights in the enterprise whose shares or voting rights are being acquired, except in the cases where the transaction results in transfer from joint control to sole control.”
¹⁵ See the CCI’s order in Sumitomo Mitsui Banking Corporation, dated September 2, 2025 in C-2025/06/1294.
¹⁶ See the CCI’s order in Curefit Healthcare Private Limited & Ors., dated December 9, 2025 in C-2025/08/1320.
¹⁷ See the CCI’s order in India Resurgence Asset Management Business Private Limited & Ors., dated November 18, 2025 in C-2025/09/1332.
¹⁸ See the CCI’s order dated April 21, 2025 in Case No. 19 of 2020 titled Kshitiz Arya & Anr. v. Google LLC & Ors.
¹⁹ An enterprise facing the CCI’s inquiry in relation to either anti-competitive vertical agreements or abuse of dominant position may file an application offering its proposal for settlement addressing the alleged contraventions, competition concerns, and the manner of implementation and monitoring thereof. Such application may be filed within 45 days (which can be extended to a further period of 30 days at the CCI’s discretion) of receipt of the DG’s investigation report. If the settlement proposal is accepted by the CCI, (i) the proceedings against such party may be closed without any finding of contravention, and (ii) any penalty proposed to be imposed by the CCI is discounted by 15%. The final CCI order agreeing to the proposal for settlement is not construed as a finding of contravention by the CCI against the settlement applicant.
²⁰ The dissent note by a Member of the CCI raised concerns on the dual structure proposed by Google, i.e., one with the ‘New India Agreement,’ and another with the existing TADA (identified as anti-competitive by the DG’s investigation report) on the ground that such dual structure places smart TV manufacturers in a position where opting for the New India Agreement incurs additional costs, while the bundled applications under the TADA remain free but come with restrictive conditions. Therefore, the dissent observes that such an arrangement is not likely to correct the existing market conditions under the TADA. Accordingly it was proposed that the concerned clauses of the TADA must be modified for complete compliance with the Competition Act, or the TADA may be wholly replaced with another agreement fully complying with the provisions of the Competition Act.
²¹ See the Supreme Court’s judgement dated May 13, 2025 in Civil Appeal Nos. 5843 of 2014 and 9998 of 2014 titled Competition Commission of India v. Schott Glass India Private Limited & Ors.
²² Section 4(2)(a)(i) of the Competition Act states as follows: “There shall be an abuse of dominant position under sub-section (1), if an enterprise or a group – directly or indirectly, imposes unfair or discriminatory condition in purchase or sale of goods or service, or condition in purchase or sale of goods or service.”
²³ Schott India was engaged in the upstream market for manufacture of neutral borosilicate tubing, whether clear or amber. Schott Kaisha was engaged in the downstream market for sale of pharmaceutical containers-ampoules, vials, cartridges and syringes. The upstream market supplied the raw material, and the downstream market transformed it into finished goods.
²⁴ See (i) the NCLAT’s judgement dated November 4, 2025 in Competition Appeal (AT) No. 1 of 2025, and (ii) the NCLAT’s order dated December 15, 2025 in I.A. No. 6817 of 2025 in Competition Appeal (AT) No. 1 of 2025, titled WhatsApp LLC vs Competition Commission of India & Ors.
²⁵ See the Supreme Court’s order dated February 23, 2026 in Civil Appeal Nos. 301-302 of 2026 titled Meta Platforms, Inc. v. Competition Commission of India & Ors.
²⁶ See the Supreme Court’s judgement dated January 29, 2025 in Civil Appeal No. 6071 of 2023 titled Independent Sugar Corporation Limited v. Girish Sriram Juneja & Ors.
²⁷ See (i) judgement of the single judge bench of the Delhi High Court dated April 24, 2024 in W.P.(C) 10332 of 2023 titled Geep Industries (India) Private Limited & Ors. V. Competition Commission of India, and (ii) judgement of the division bench of the Delhi High Court dated November 1, 2025 in LPA 727 of 2024 titled Competition Commission of India v. Geep Industries & Ors.
²⁸ The erstwhile Competition Commission of India (Manner of Recovery of Monetary Penalty) Regulations, 2011, and the current Competition Commission of India (Manner of Recovery of Monetary Penalty) Regulations, 2025.
²⁹ See the Bombay High Court’s judgement dated September 11, 2025 in Writ Petition No. 2887 of 2025 titled Asian Paints Limited v. Competition Commission of India & Anr.
³⁰ See the CCI’s order dated July 1, 2025 in Case No. 32 of 2024 titled Grasim Industries Limited (Birla Paints Division) v. Asian Paints Limited.
³¹ See the CCI’s order dated September 8, 2022 in Case No. 36 of 2019 titled JSW Paints Private Limited v. Asian Paints Limited.
³² Based on Section 26(2A) of the Competition Act which states as follows: “The Commission may not inquire into agreement referred to in section 3 or conduct of an enterprise or group under section 4, if the same or substantially the same facts and issues raised in the information received under section 19 or reference from the Central Government or a State Government or a statutory authority has already been decided by the Commission in its previous order.”
³³ See the CCI’s order dated March 12, 2026 in Case No. 46 of 2021 titled Showtyme v. Big Tree Entertainment Private Limited (BookMyShow).
³⁴ See the CCI’s order dated February 12, 2026 in Case No. 05 of 2019 titled Matrix Info Systems Private Limited v. Intel Corporation.
³⁵ See CCI’s order dated February 4, 2026 in Case No. 44 of 2025 titled Kartikeya Rawal v. InterGlobe Aviation Limited.
³⁶ See the CCI’s order dated March 11, 2026 in Case No. 42 of 2025 titled Kannadiputhur Sundararaman Suresh v. InterGlobe Aviation Limited & Anr.
³⁷ Section 4(2)(b) of the Competition Act states: “There shall be an abuse of dominant position under sub-section (1), if an enterprise or a group…. (b) limits or restricts– (i) production of goods or provision of services or market therefor; or (ii) technical or scientific development relating to goods or services to the prejudice of consumers…” Also see footnote 22 above.
³⁸ See (i) the NCLAT’s judgement in Competition Appeal (AT) No. 5 of 2023 titled Swapan Dey v. Competition Commission of India & Ors., and (ii) the Supreme Court’s order dated February 2, 2026 in Civil Appeal No. 519 of 2026 titled Competition Commission of India v. Mr. Swapan Dey & Anr. The Supreme Court is currently hearing this case only on the issue of jurisdiction.
Also see (i) the Supreme Court’s order dated September 2, 2025 in Special Leave to Appeal (C) No. 25026 of 2023 titled Monsanto Holdings Private Limited & Ors., and (ii) the Delhi High Court’s judgement dated July 13, 2023 in LPA No. 247 of 2016 titled Telefonaktiebolaget LM Ericsson v. Competition Commission of India & Ors.
³⁹ See the Kerala High Court’s judgement dated December 3, 2025 in W.A. No. 1551 of 2025 titled Jiostar India Private Limited v. Competition Commission of India & Ors.
⁴⁰ See the CCI’s order dated November 28, 2024 in Case No. 42 of 2022 titled Winzo Games Private Limited v. Google LLC & Ors. and the CCI’s notice inviting comments on Google’s commitment proposal (available here).
⁴¹ An enterprise facing the CCI’s inquiry in relation to either anti-competitive vertical agreements or abuse of dominant position may file an application offering its proposal for commitment addressing the alleged contraventions, competition concerns, and the manner of implementation and monitoring thereof. Such application may be filed within 45 days (which can be extended to a further period of 30 days at CCI’s discretion) of receipt of the CCI’s investigation initiation order or before the party receives the DG’s investigation report. If the proposal for commitment is accepted by the CCI, the proceedings against such party may be closed without any finding of contravention. The final CCI order agreeing to the proposal for commitment is not construed as a finding of contravention by the CCI against the commitment applicant.
⁴² See the CCI’s order dated August 1, 2025 in Case No. 23(1) of 2024 titled Alliance of Digital India Foundation v. Alphabet Inc. & Ors.
⁴³ The various operators in the value chain of display advertising intermediation ecosystem are collectively called the ‘AdTech Stack’. It was alleged that Google is the only company that offers AdTech services across the entire AdTech supply chain.
⁴⁴ The Publishers Case deals with (i) Google’s alleged unfair conditions in its search ads policies; (ii) Google’s alleged leveraging of its position in the general search market to enter and protect its position/ increase profit in the online advertising market; (iii) alleged tying and bundling among Google’s AdTech offerings; and (iv) alleged opacity in ad placement.
⁴⁵ See the CCI’s order dated August 1, 2025 in Case No. 23(2) of 2024 titled Alliance of Digital India Foundation v. Alphabet Inc. & Ors.
⁴⁶ See (i) the CCI’s order dated January 31, 2018 in Case Nos. 07 & 30 of 2012 titled Matrimony.com Limited v. Google LLC & Ors., and (ii) the CCI’s order dated July 12, 2018 in Case Nos. 06 & 46 of 2014 titled Shri Vishal Gupta v. Google LLC & Ors.
⁴⁷ See CCI’s order dated October 6, 2025 in Case No. 07 of 2025 titled Liberty Infospace Private Limited v. Alphabet Inc. & Ors.
⁴⁸ See the CCI’s order dated March 24, 2026 in Case No. 17 of 2025 titled M/s Zucol Solutions Private Limited v. Google India Private Limited.
⁴⁹ See the judgement of (i) the division bench of the Delhi High Court dated April 15, 2026 in LPA 266 of 2026 titled International Flavours and Fragrances Inc. v. Competition Commission of India & Ors., and (ii) the single judge of the Delhi High Court dated February 23, 2026 in W.P.(C) 2527 of 2026 titled International Flavours and Fragrances Inc. v. Competition Commission of India & Ors.
⁵⁰ See the CCI’s Market study on Artificial Intelligence and Competition, available here.
⁵¹ See Ministry of Corporate Affairs – Request for Proposal to undertake a Market Study on “Qualitative and Quantitative thresholds for Big Tech Companies and Core Digital Services,” available here.
⁵²An enterprise may be designated an SSDE if, in respect of a ‘Core Digital Service’ it demonstrates ‘significant presence’ in India (based on certain quantitative thresholds or qualitative criteria to be determined by the CCI).
⁵³ See Ministry of Corporate Affairs – Reply to Rajya Sabha Question No. 209 (268th Session), available here.
⁵⁴ A “Core Digital Service” includes any of the following: (i) online search engines; (ii) online social networking services; (iii) video-sharing platform services; (iv) interpersonal communications services; (v) operating systems; (vi) web browsers; (vii) cloud services; (viii) advertising services; and (ix) online intermediation services.
⁵⁵ See the CCI’s Diagnostics Tool for Public Procurement Officers, 2025, available here.
⁵⁶ See news reports, (i) “CCI raids paper mills in antitrust probe over supplies to schools body, sources say,” Economic Times, dated November 12, 2025, available here (ii) “CCI raids steel makers Jindal SAW, Maharashtra Seamless in antitrust case,” CA Alley, dated September 16, 2025, available here.

This insight has been authored by Akshat Kulshrestha (Partner), Prerana De (Principal Associate), Sehaj Mahajan (Associate) and Ritik Mohapatra (Associate). They can be reached on akulshrestha@snrlaw.in, preranade@snrlaw.in, smahajan@snrlaw.in and rmohapatra@snrlaw.in, respectively, for any questions. This insight is intended only as a general discussion of issues and is not intended for any solicitation of work. It should not be regarded as legal advice and no legal or business decision should be based on its content.
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