Antitrust And Competition Newsletter | September 2025

As we enter a new season, this edition of our newsletter features consolidated competition law updates from the past four months-July, August, September and October 2025. In recent months, significant developments have occurred on the antitrust front. The Hon'ble Supreme Court of India upheld the penalty imposed by the Competition Commission of India ("CCI") on the office bearers of the Kerala Film Exhibitors Federation, which had previously been set aside by the erstwhile appellate tribunal. Separately, the Supreme Court also dismissed the CCI's petition challenging the Delhi High Court's stay on antitrust proceedings against Ericsson and Monsanto.

Additionally, the CCI imposed an antitrust penalty of INR 2,56,649 (approximately USD 2,923) on the Federation of Publishers' and Booksellers' Association in India for violating Section 3(3) of the Competition Act, 2002 ("Act"), and has ordered separate antitrust investigations against Asian Paints Limited, PVR Inox Limited, Rashtriya Chemicals and Fertilizers Limited, and others. On the merger control front, the CCI granted approvals to several notable combinations, including the investment by British International Investment plc in Renew Photovoltaics Private Limited, and the acquisition of a 2.143% shareholding in Billionbrains Garage Ventures Limited (Groww) by Viggo Investment Pte. Ltd., among others.

To keep our readers updated, this edition provides a quick snapshot of the regulation of resale price maintenance under Indian competition law, summaries of judgments and orders passed by the Supreme Court, National Company Law Appellate Tribunal, followed by orders passed and combinations approved by the CCI, and information on upcoming antitrust events.

Regulation of Resale Price Maintenance under Indian Competition law

The provisions of Section 3(4) of the Act i.e., The Competition Act, 2002 (as amended in 2023), regulate vertical agreements in India and, inter alia, prohibit any agreement that results in resale price maintenance. An agreement of "resale price maintenance" is defined at Explanation (e) to Section 3(4) of the Act to include, in the case of any agreement to sell goods or provide services, any direct or indirect restriction that the prices to be charged on the resale by the purchaser shall be the prices stipulated by the seller unless it is clearly stated that prices lower than those prices may be charged.

In India, vertical agreements are not considered per se illegal and are tested under the rule of reason. In terms of Section 3(4) of the Act, only those vertical agreement(s) are prohibited which causes or are likely to cause an appreciable adverse effect on competition in India, in terms of factors enumerated under Section 19(3) of the Competition Act, which inter alia, includes – i) creation of barriers to new entrants in the market; ii) driving existing competitors out of the market; iii) foreclosure of competition; iv) benefits or harm to consumers; v) improvements in production or distribution of goods or provision of services; and vi) promotion of technical, scientific and economic development by means of production or distribution of goods or provision of services.

Judgements and Orders Passed by Supreme Court of India

The Supreme Court of India clarifies no second show cause notice is required for imposition of penalty under the Competition Act

Competition Commission of India vs. Kerala Film Exhibitors Federation & Ors. (Civil Appeal No. 9726 of 2016)

The Supreme Court of India, vide its judgement dated 26.09.2025, clarified that the Competition Act, 2002 does not mandate a separate show-cause notice at the penalty stage once a notice concerning alleged contravention has already been issued by the CCI.

In the instant matter, an appeal before the Supreme Court was filed by the CCI against the judgement dated 19.04.2016 passed by the erstwhile Competition Appellate Tribunal ("COMPAT") whereby the penalty imposed by the CCI upon Kerala Film Exhibitors Federation ("KFEF") for contravention of the provisions of Section 3(3)(b) of the Act was upheld. However, the penalty upon office bearers of KFEF and the behavioral remedies imposed on them were set aside by the COMPAT on the grounds that no separate notice for imposition of penalty and an opportunity of being heard was given by the CCI to the office bearers of KFEF.

The Supreme Court, in its judgment, noted that in the said matter, the report of the Director General was concurred by the CCI, and a notice along with the said report was issued by the CCI to KFEF and its concerned office bearers, which was sufficient to comply with the provisions of the Act. The Court therefore restored the findings of the CCI in their entirety.

The Supreme Court of India upheld Delhi High Court's stay on anti-competitive proceedings against Ericsson and Monsanto

Competition Commission of India vs. Telefonaktiebolaget LM Ericsson (PUBL) & Ors (Civil Appeal No. 9726 of 2016)

The Supreme Court of India, vide order dated 02.09.2025, disposed of multiple special leave petitions arising out of the Delhi High Court's judgement dated 13.07.2025 whereby the anti-competitive proceedings against Ericsson and Monsanto were quashed on the grounds that a settlement had been reached between the parties and that the CCI lacked jurisdiction over actions of enterprises that are in exercise of their rights as a patentee.

In view of the peculiar facts and circumstances of the case and noting that the original complainants/informants have raised no objections to the High Court's findings in the impugned judgment, the Supreme Court decided not to interfere with the said judgment, leaving any questions of law open to be agitated in an appropriate future case.

Orders passed by National Company Law Appellate Tribunal

The NCLAT upholds CCI's dismissal of abuse of dominance allegations against Vifor International AG concerning iron injectables

Mr. Swapan Dey vs. Competition Commission of India & Ors. (Competition Appeal (AT) No. 5 of 2023)

The NCLAT, vide order dated 30.10.2025, upheld the CCI's order of closure in relation to information filed against Vifor International (AG). The information had alleged de facto exclusive agreements with Emcure and Lupin for Ferric Carboxymaltose ("FCM") injectables, refusal to grant voluntary licences for patents held by it, and abuse of dominant position in the market for FCM injectables by limiting production, imposing unfair and discriminatory prices, and leveraging its upstream monopoly to protect its downstream market position. Relying on judicial guidance from the Delhi High Court and the Supreme Court in the Ericsson and Monsanto cases (discussed above), the NCLAT dismissed the appeal on the ground that the CCI lacks the power to examine the allegations against Vifor International (AG), as the subject matter FCM is protected by a patent and the dispute therefore falls within the ambit of the Patents Act, 1970.

Penalties imposed and investigations ordered by the Competition Commission of India

Competition Commission of India imposes a penalty of INR 2,56,649/- (approx. USD 2923) up on Federation of Publisher's and Bookseller's Association for indulging in anti-competitive practices in violation of Section 3(3) of the Act

In Re: Pranav Gupta And Federation of Publishers' and Booksellers' Association in India (Case No. 38 of 2021)

The CCI, vide order dated 01.07.2025 imposed a penalty of INR 2,56,649/- (approx. USD 2923) upon Federation of Publishers' and Booksellers' Association in India ("FPBAI") for violation of provisions of Section 3(3)(a) and 3(3)(b) read with Section 3(1) of the Act by indulging in – (i) fixation of higher current exchange rates at which member booksellers/publishers imported books and journals in India; (ii) issuing terms and conditions of supply to be followed by member booksellers/publishers; and (ii) issuing list of approved suppliers of journals/subscription agents for purchase of books by libraries and institutions. Additionally, the CCI also directed FPBAI to spread awareness about its current order and previous order passed in Case No. 33 of 2019 whereby FPBAI was ordered to cease and desist from indulging in declaration/controlling of discounts to be offered by member booksellers/publishers and submit a compliance report to the CCI within two (2) months.

In its analysis, the CCI found that FPBAI through its Good Offices Committee ("GOC") fixed inflated foreign current exchange rate for ten (10) major currencies which were regularly published under the heading "Terms of Supplies to Booksellers, Libraries and Institutions". It was observed that the said rates were followed by the member booksellers/publishers for importing books & journals in India and the same resulted in financial losses to booksellers. In this regard, the CCI held that the said practice of GOC amounts to price fixation under Section 3(3)(a) of the Act as GOC exchange rates has direct bearing on the final prices as higher GOC rates means higher final price to be paid by the buyer. With respect to allegations concerning issuing of terms and conditions of supply, the CCI noted that GOC of FPBAI issued monthly circulars with specific terms of supply such as price, credit period, interest rates etc. which were mandatorily followed while supplying books, journals and e-resources to libraries, schools, and other consumers. The CCI held that such terms violated provisions of Section 3(3)(b) of the Act as the same had effects of limiting or controlling the market for book trade and pose difficulties for new entrant booksellers in the market. Lastly, with respect to FPBAI issuing a list of approved suppliers of journals/subscription agents along with its circulars, in furtherance of its already existing advisories/ appeals to libraries and other institutions to purchase books only from its approved vendors, the CCI held that such conduct of FPBAI is in contravention of Section 3(3)(b) of the Act as the same distorts the level playing field and tilts it in favour of the approved vendors/ members of FPBAI by foreclosing participation of non-members.

Competition Commission of India orders probe against PVR Inox limited for alleged abuse of dominant position

In Re: The Film and Television Producer's Guild of India Limited And UFO Moviez India Limited & Ors. (Case No. 42 of 2023)

The CCI, vide order dated 30.09.2025, ordered a probe against PVR INOX Limited for alleged abuse of dominant position in the market for provision of digital cinema equipment ("DCE") at theatres in India. An information was filed by the Film and Television Producer's Guild of India Limited against UFO Moviez Limited ("OP-1"), Qube Cinema Technologies Private Limited ("OP-2") and PVR INOX Limited ("OP-3") for alleged contravention of provisions of Section 3 and 4 of the Act. The information against OP-1 and OP-2 was closed by the CCI under Section 26(2A) of the Act, as the same have been already adjudicated in Case No. 11 of 2020. However, with respect to allegations levelled against OP-3, the CCI formed its prima facie opinion and ordered an investigation to be conducted by the Director General. As against OP-3, the informant alleged that it has abused its dominant position by offering discriminatory virtual print fee ("VPF") to the producers, imposing unfair conditions upon small and medium producers, indulging in denial of market access to producers through exclusionary practices, among others.

Competition Commission of India expands investigation into Google's conduct in online display advertising and AdTech intermediation services, while closing ADIF's allegations regarding online search advertising

In Re: Alliance of Digital India Foundation And Alphabet Inc. & Ors. (Case No. 23(1) of 2024)

The CCI, vide order dated 01.08.2025 admitted information filed by Alliance of Digital India Foundation ("ADIF") against Google, alleging abuse of dominance in online display advertising services and AdTech intermediation services. The CCI has clubbed the present matter with Case Nos. 41 of 2021, 10 of 2022, 36 of 2022 and 34 of 2024, wherein similar investigation(s) are already underway. In its information, ADIF alleged that Google has abused its dominant position online display advertising and AdTech intermediation services by contravening the provisions of – (i) Section 4(2)(a)(i), 4(2)(b)(i) and 4(2)(c) of the Acy by tying its own services on the Supply Side Platform Ad Server viz. DoupleClick for Publisher and Google Display & Video 360 ("DV360") with Ad Exchange, and offering them as a single Google Ad Manager function; and (ii) Section 4(2)(c), 4(2)(d) and 4(2)(e) of the Act by linking access to its vertical's YouTube ad inventory to the use of DV360.

Additionally, ADIF also made allegations of abuse of dominance by Google in the online search advertising market through its Ads Policies. However, the CCI closed the said allegations under Section 26(2A) of the Act, noting that the similar allegations have already been adjudicated by it in Case no. 07 & 30 of 2012.

Competition Commission of India orders investigation against Rashtriya Chemicals and Fertilizers Limited for tying of other products with the sale of urea

In Re: Shri Raghunath Patil And Rashtriya Chemicals and Fertilizers Limited (Case No. 03 of 2025)

The CCI, vide order dated 06.08.2025 ordered an investigation against Rashtriya Chemicals and Fertilizers Limited ("RCFT") for alleged violation of Section 3(4) and Section 4 of the Act. The informant alleged that RCFT has indulged in tying of other products with the sale of urea and has violated the provisions of Section 4 and Section 3(4) of the Act. It was alleged that since the maximum selling price of Urea is fixed by the Government, the manufacturers cannot increase its price and take advantage by compelling dealers and farmers to purchase additional (non-subsidized) products along with Urea.

The CCI perused the evidence placed on record by the informant and noted that the practice of tie-in of other products along with Urea and DAP is widespread. The CCI further noted that RCFT appears to be a significant market player in the supply of Urea in the State of Maharashtra and its conduct of tying sale of other products to the sale of Urea to farmers of Maharashtra appears to give rise to appreciable adverse effect on competition in India. Regarding allegations pertaining to abuse of dominance, the CCI noted that RCFT appears to be dominant in the relevant market of 'sale and supply of Urea in the State of Maharashtra' due to its consistent high market share and that its alleged conduct of imposing condition of purchase of other products with the purchase of Urea appears – (i) to be an imposition of unfair condition and supplementary obligations in violation of Section 4(2)(a)(i) and 4(2)(d) of the Act; and (ii) leveraging of its dominant position in the market for sale and supply of Urea to enter into or protect its position in the market for other products in violation of Section 4(2)(e) of the Act.

Competition Commission of India directs investigation against Asian Paints for abusing its dominant position

In Re: Grasim Industries Ltd. (Birla Paints Division) and Asian Paints Ltd (Case No. 32 of 2024)

The CCI, vide its order dated 01.07.2025, directed an investigation against Asian Paints Ltd. ("APL") for alleged abuse of dominant position. The information was filed by Grasim Industries Limited (Birla Paints Division) ("Informant") alleging that APL has abused its dominant position by offering arbitrary and discriminatory additional/extra discounts/condonations/incentives such as foreign travel, etc. in exchange for exclusivity and exercising de facto exclusivity upon dealers by threatening them against stocking the Informant's product by, inter alia, reducing credit limit, revising service levels, increasing/enhancing sales targets, recalling their benefits (like foreign travel) for dealers engaging with the Informant. The informant alleged that APL violated provisions of – (i) Section 4(2)(a) by imposing discriminatory and unfair conditions upon dealers in sale of decorative paints to not deal with the Informant; (ii) Section 4(2)(b) by limiting and restricting technical development of decorative paints market by restricting dealers from using more technologically advanced tinting machines of the Informant; (iii) Section 4(2)(c) by indulging in denial of market access to competitors like the Informant through input foreclosure; and (iv) Section 4(2)(d) by imposition supplementary obligations upon dealers by offering incentives not related to their performance.

The CCI after considering the information and preliminary submissions of the parties, defined the relevant market as 'the market for manufacture and sale of decorative paint in the organized sector in India' and on the basis of market share of APL and other factors found APL to be dominant in the said relevant market. With regard to the abuse, the CCI took note of the evidence placed on record by the informant and prima facie opined that APL has – (i) acted in violation of Section 4(2)(a)(i) of the Act by way of restraining its dealers from dealing with its competitors like the Informant and enforcing exclusivity upon such dealers by coercing them against stocking other manufacturers' paints, discouraging them from using tinting machines of others, offering discriminatory additional discounts/condonations/incentives to its dealers not linked to the performance/sales of the dealer etc.; (ii) imposed supplementary obligations upon dealers in contravention of Section 4(2)(d) of the Act by not following any uniform policy for offering discounts/condonations/incentives etc.; and (iii) restrained third party suppliers of essential raw materials, warehousing landlords, C&F Agents and Transporters, from engaging with the Informant amounting to a contravention of Section 4(2)(c) of the Act.

The aforesaid order of the CCI was subsequently challenged by the informant before the Bombay High Court in Writ Petition No. 2887 of 2025, on the grounds that the probe into the allegations was barred under Section 26(2A) of the Act, as the matters had already been decided by the CCI in Case Nos. 36 of 2019 and 17 of 2021. The Bombay High Court dismissed the petition, noting that the allegations were based on fresh facts and evidence, and that Section 26(2A) is only an enabling provision to avoid duplication and does not create any jurisdictional bar on the CCI.

Information(s) dismissed, and investigations closed by the Competition Commission of India

Competition Commission of India closes an information against GMR Hyderabad International Airport Limited for alleged abuse of position

In Re: Air Works India (Engineering) Private Limited And GMR Hyderabad International Airport Limited & GMR Aero Technic Limited (Case No. 30 of 2019)

The CCI, vide its order dated 15.09.2025 closed an information filed against GMR Hyderabad International Airport Limited ("OP-1") and its subsidiary GMR Aero Technic Limited ("OP-2") filed by Air Works India (Engineering) Private Limited ("Informant"), an entity engaged in the business of providing Line Maintenance Services("LMS") and Base Maintenance Services ("BMS"). The Informant in its complaint alleged that OP-1 abused its dominant position in the market for LMS at Rajiv Gandhi International Airport ("RGIA") and acted in violation of provisions of Section 4(2)(b)(i), 4(2)(c) and 4(2)(e) of the Act by – (i) limiting and restricting services of the Informant at RGIA; (ii) denying market access to Informant by refusing to renew its license for space at the airside of RGIA required for the provision of LMS; and (iii) leveraging its dominant position at the airport to eliminate competition in the market of provision of LMS wherein OP-2 also functions. The CCI after considering the information, formed its prima facie view and passed an order dated 03.10.2019 directing the Director General ("DG") to investigate the matter. Subsequently, the OPs filed a writ petition before the High Court of Telangana against the said order, which was dismissed by the court. Separately, the Informant also approached the CCI for withdrawal of the Information after arriving at a settlement with the OPs. The said application was rejected by the CCI, an order thereto was also challenged by the parties before the High Court of Telangana, which was also dismissed by the court.

In its analysis, the CCI delineated the upstream and downstream relevant market(s) as 'market for provision of access to airport facilities/premises at RGIA' and 'market for provision of LMS', respectively. With respect to dominance of OP-1 in the upstream relevant market, the CCI noted that OP-1 enjoys monopoly at RGAI by virtue of its concessionaire agreement which granted it the exclusive right to manage and operate RGAI for a period of thirty (30) years and thus in view of Section 19(4)(g) of the Act, OP-1 is dominant in the said market. Regarding allegations of abuse in violation of Section 4(2)(b), the CCI disagreed with the findings of the DG that OP-1 restricted and limited services of the Informant as it was offering its services as per the scheduled timings of airlines using vehicles, tools and engineering based on necessary passes issued by OP-1. The CCI also noted that space at the airport is not an essential ingredient for providing LMS providers and there are other LMS providers which operate without space at the airport. Further, with respect to allegations of denial of market access under Section 4(2)(c) of the Act, the CCI noted that the reason for non-renewable of the license of the informant was the space constraints on the airside and in view of exclusive rights granted to OP-1 under the concessionaire agreement, OP-1 can take executive decisions in pursuance of the same as per law. The CCI rejected DG's findings and noted that the Informant continued to operate even without space at the airport and the same cannot be construed as denial of market access in terms of the Act. Lastly, with respect to allegations of leveraging of dominance position by OP-1 in the upstream market to benefit its own subsidiary i.e., OP-2 in the downstream market, the CCI noted that OP-1 in its emails to airlines did not urge them to choose OP-2 as an alternate vendor and that OP -2 got the LMS work only through a bidding process and in case it was approached by the airline itself. Therefore, no contravention of Section 4 was found by the CCI, and matter was accordingly directed to be closed.

Competition Commission of India closes information against Google for alleged abuse of dominance in termination of developer account

In Re: Liberty Infospace Pvt. Ltd. And Alphabet Inc & Ors. (Case No. 07 of 2025)

The CCI, vide order dated 06.10.2025, closed an information filed by Liberty Infospace Pvt. Ltd. against Alphabet Inc, Google LLC, and Google India Private Limited (collectively referred to as "Google"), alleging abuse of dominance by Google in the app store market for the android OS. The informant alleged that Google in exercise of its dominance in the relevant market has unilaterally terminated its developer account without assigning any reasons. The informant further alleged that in order to get apps listed on the Google Play Store, app developers are forced to enter into the standard and on-side Google Play Developer Distribution Agreement ("GPDDA") and adhere to related one-sided Google Play Developer Program Policies ("GPDDA").

While referring to its observations in Case No. 07 of 2020, 14 of 2021 and 35 of 2021, the CCI in the instant case, defined the relevant market as "market for app stores for Android OS in India" and found Google to be dominant in the said market. With respect to abuse, the CCI noted that Google terminated the developer account of the informant as per Google's policy and that GPDDA and GPDDP are standard form contracts which have already been examined by the CCI in Case No. 39 of 2018. In view of the said observations, the CCI dismissed the allegations against Google and passed an order under Section 26(6) of the Act.

Competition Commission of India dismisses anti-competitive allegations against ICICI Securities limited, Stock Exchange of India Limited and BSE Limited

In Re: Mr. Krishna Kumar Agrawal And ICICI Securities Limited & Ors. (Case No. 23 of 2025)

The CCI, vide order dated 15.09.2025 closed the information filed by Mr. Krishna Kumar Agrawal against ICICI Securities Limited ("OP-1"), National Stock Exchange of India Limited ("OP-2"), and BSE Limited ("OP-3"). The Informant, an Authorised Person("AP") of OP-1 registered with OP-2 and OP-3, alleged that the conduct of mass termination of AP agreements by OP-1 amounts to violation of provisions of Sections 3(3), 3(4) and 4 of the Act.

The informant alleged that – (i) OP-2 and OP-3 have facilitated a structurally anti-competitive framework in contravention of Section 3(3) of the Act by mandating identical AP Agreement formats and enforcing them uniformly, leaving APs with no bargaining power or competitive space; (ii) the terms of AP agreements contravenes provisions of Section 3(4) of the Act, as the same give rise to refusal to deal as the clients acquired by APs cannot be ported or serviced after termination, tie-in arrangement as APs are compelled to register with the same broker across both OP-2 and OP-3, and exclusive distribution obligations where an AP is permitted to be affiliated with only 1 broker per exchange; and (iii) OP-1 has abused its dominant position in contravention of Section 4 of the Act by imposing unfair contractual terms.

The CCI, after perusing the information, opined that provisions of Section 3(3) of the Act are not attracted as the standardized AP Agreement flows directly from SEBI's regulatory framework (Circulars dated 06.11.2009 and 03.12.2009) and are intended to ensure uniformity and investor protection. With respect to contravention of provisions of Section 3(4) of the Act, the CCI found no merit in the said allegations, as APs operate as agents under a SEBI-regulated structure and no significant market power is held by OP-1 in the market for securities intermediation services in India. Lastly, with respect to allegations pertaining to abuse of dominant position, the CCI observed that the market for securities broking through APs in India is highly competitive, and OP-1 is not dominant therein.

Competition Commission of India closes information filed against Emaar India Limited for abuse of dominance concerning its Marbella project in Gurugram

In Re: XYZ (confidential) And Emaar India Limited & Ors. (Case No. 10 of 2025)

The CCI, vide order dated 29.08.2025 closed an information filed by XYZ (confidential) against – Emaar India Limited ("OP-1"), Emaar India Community Management Private Limited ("OP-2"), Department of Town and Country Planning ("OP-3"), Senior Town Planner, Gurugram ("OP-4"), District Town Planner, Gurugram ("OP-5"), and Union of India through Chief Secretary, Foreign Investment at DPIIT ("OP-6") alleging violation of provisions of Section 3(4) and 4 of the Act concerning OP-1's "signature villa community" of "Marbella" project in Sector 66, Gurugram. The informant alleged that OP-1 has abused its dominance by arbitrarily introducing builder floors and non-villa units in the said project in violation of the Builder Buyer Agreements executed between villa owners and OP-1.

The CCI its analysis defined the relevant market as "the provision of services for development and sale of villa in Gurugram". With respect to dominance, CCI observed that OP-1 does not appear to be dominant in the relevant market as there are other reputed real estate developers in the market such as DLF, Godrej Properties, Tata Housing, Signature Global, Vatika Group, ATS Group, and Tulip Infratech who have been building villas in Gurugram since 2010. Thus, no case of contravention of Section 4 by OP-1 was found by the CCI. With regards to allegations of abuse of dominance by OP-2, CCI noted that OP-1 and OP-2 are a part of the same group. Lastly, with respect to contravention of Section 3(4) of the Act, it was noted that no evidence has been provided by the informant in this regard.

Competition Commission of India closes information concerning cartelization and bid-rigging in public auction of coal blocks for lack of evidence and being barred by limitation

In Re: Deepika And Calcutta Electric Supply Corporation & Ors (Case No. 02 of 2025)

The CCI, vide its order dated 31.07.2025, closed an information filed against Calcutta Electric Supply Corporation and fourteen (14) other opposite parties, alleging cartelization and bid-rigging in public auction of coal blocks in the years 2015 and 2023. The informant alleged bid-rigging by the opposite parties in 1st, 2nd and 16th tranche of coal mine auctions.

In view of Hon'ble Supreme Court ruling in Rajasthan Cylinders and Containers Ltd. and Others v. Union of India and Others, (2020) 16 SCC 615, the CCI consulted Ministry of Coal ("MoC") before coming to a conclusion of cartelization/bid-rigging. On the basis of comments received from the MoC, the CCI observed that there appeared to be no grievance or apprehension on the part of the procurer regarding any cartelization or bid-rigging in the 1st and 2nd or 16th tranche of coal mine. Further, the CCI noted that the informant had placed evidence on record concerning cartelization alleged in the 16th tranche of coal mines auction. Whereas, with respect to 1st and 2nd tranche of auctions that took place in the year 2015, the CCI rejected the allegations on the grounds that they were filed nearly ten (10) years later and were thus barred by limitation under the Act.

Competition Commission of India closes information against Cholamandalam MS General Insurance Company Ltd. and Central Bank of India for being barred by limitation

In Re: P. R. Ganesan and Cholamandalam MS General Insurance Company Limited & Ors. (Case No. 04 of 2025)

The CCI, vide its order dated 07.07.2025, closed an information filed against Cholamandalam MS General Insurance Company Limited ("OP-1") and Central Bank of India ("OP-2") for being barred by limitation. The informant in alleged abused of dominant position by OP-1 and tie-in arrangement between OP-1 and OP-2 in contravention of provisions of Section 4 and Section 3(4) of the Act, respectively. The CCI in its order observed that the information has been filed beyond the statutory period of three (3) years from the date on which the cause of action arose initially. Be that as it may, with respect to allegations of abuse of dominance, the CCI noted that even otherwise the general insurance market is characterized by the presence of several major competitors such as Life Insurance Corporation of India, HDFC Life, SBI Life, ICICI Prudential etc. and thus, OP-1 does not appear to be dominant in the general insurance market. In the absence of dominance, the issue raised by the informant does not raise any competition concerns.

Combinations Approved by the Competition Commission of India

• CCI approves proposed acquisition of Cloud4C Services Pte. Ltd and Cloud4C Services Private Limited by Capgemini SE.¹
• CCI approves the acquisition of 49.99% equity share capital of Thriveni Pellets Private Limited by Lloyds Metals and Energy Limited.²
• CCI approved 100% acquisition of equity shares by IRB InvIT of – IRB Hapur Moradabad Tollway Limited; Kaithal Tollway Limited; and Kishangarh Gulabpura Tollway Limited.³
• CCI approved exit of Canada Pension Plan Investment Board from Island Star Mall Developers Private Limited and acquisition of remaining 49% equity by Phoenix Mills Limited.⁴
• CCI approved acquisition of shareholding in V.I.P. Industries Limited by Multiples Private Equity Fund IV, Multiples Private Equity Gift Fund IV, Samvibhag Securities Private Limited, Mr. Mithun Padam Sacheti and Mr. Siddhartha Sacheti.⁵
• CCI approved acquisition and subscription of certain equity shares by Platinum Jasmine A 2018 Trust in Micro Life Sciences Private Limited.⁶
• CCI approved proposed acquisition of shareholding in Jaiprakash Associates Limited by Adani Enterprises Limited and Adani Infrastructure and Developers Private Limited.⁷ The said approval was sought pursuant to a corporate insolvency resolution process (CIRP) of Jaiprakash Associates Limited under the Insolvency and Bankruptcy Code, 2016.
• CCI approved acquisition of certain equity shareholding of Theobroma Foods Private Limited by Aqua Investments Limited, Infinity Partners and Atreides Investments B.V.⁸
• CCI approved indirect acquisition of all the outstanding shares and sole control of Skechers U.S.A., Inc. by 3G Capital Partners LP.⁹
• CCI approved proposed 100% acquisition of shareholding in Jaiprakash Associates Limited by Dalmia Cement (Bharat) Limited. The said approval was sought pursuant to a corporate insolvency resolution process (CIRP) of Jaiprakash Associates Limited under the Insolvency and Bankruptcy Code, 2016.¹⁰
• CCI approved acquisition of 40% shareholding of PSA Bharat Investments Pte. Ltd. by PSA India Pte. Ltd.¹¹
• CCI approved acquisition of 100% shareholding of SMC Power Generation Limited by Rungta Sons Private Limited.¹²
• CCI approved – (i) subscription of 2,05,02,939 share warrants (i.e., up to ~4.95% of the paid-up share capital) of 360 ONE WAM Limited by USB AG; (ii) transfer of 'portfolio management service' business of Credit Suisse Securities (India) Private Limited ("CS Securities") to 360 ONE Portfolio Managers Limited; (iii) transfer of 'stock broking services' business and 'financial product distribution services' business of CS Securities to 360 ONE Distribution Services Limited; (iv) transfer of entire loan portfolio as a part of 'lending and financing' business of UBS Finance India Private Limited to 360 ONE Prime Limited; and (v) strategic collaboration between 360 ONE WAM Limited and USB AG.¹³
• CCI approved investment by British International Investment plc in Renew Photovoltaics Private Limited through subscription of securities.¹⁴
• CCI approved the acquisition by – Peony Properties Private Limited; TPG REGen SG Pte. Ltd.; Mavco Investments Private Limited; and Tikri Investments, of businesses of Siemens Gamesa Renewable Power Private Limited relating to the manufacture and assembly of onshore wind turbine generators and the operation, maintenance, and technical services of wind turbines and/or onshore wind power projects.¹⁵
• CCI approved acquisition of 2.143 % shareholding of Billionbrains Garage Ventures Limited (Groww) by Viggo Investment Pte. Ltd.¹⁶
• CCI approved combination relating to investment by – (i) Kedaara Sapphire Holding; and (ii) Kedaara Capital Fund IV AIF, in SmartShift Logistics Solutions Private Limited.¹⁷
• CCI approved the acquisition by Anantam Highway Trust ("InvIT") through its Investment Manager, of 49% shareholding of Poondiyankuppam Highways Limited, and 100% shareholdings of SPVs – (i) Dodaballapur Hoskote Highways Limited; (ii) Repallewada Highways Limited; (iii) Dhrol Bhadra Highways Limited; (iv) Narenpur Purnea Highways Limited; (v) Villuppuram Highways Limited; (vi) Bangalore Malur Highways Limited; (vii) Malur Bangarpet Highways Limited; and (viii) DPJ Pollachi HAM Project Private Limited.¹⁸

Mark Your Calendar: Upcoming Events!

• Global Forum on Competition 2025 scheduled on 1-2 December 2025 at Paris (click here).
• CBA Competition Law Fall Conference scheduled on 20-21 November 2025 at Ottawa (click here).
• The Nordic Competition Law Summit 2025 scheduled on 26 -27 November 2025 at Copenhagen, Denmark (click here).
• 19th AAI Annual Private Antitrust Enforcement Conference scheduled on November 6, 2025 at Washington, D.C. (click here).
• The Competition Law & Artificial Intelligence Summit - 2nd Annual scheduled on 2nd December 2025 at London (click here).
• CII Annual Conference on Competition Law and Practice 2026 scheduled on 16th January 2026 at Mumbai, India (click here).
• 35th Annual IBA Communications and Competition Law Conference scheduled from 27-28 April 2026 at Singapore (click here).

Footnotes

1. C-2025/08/1322

2. C-2025/09/1324

3. C-2025/08/1317

4. C-2025/08/1310

5. C-2025/07/1305

6. C-2025/07/1304

7. C-2025/07/1302

8. C-2025/07/1298

9. C-2025/06/1297

10. C-2025/06/1295

11.C-2025/06/129

12. C-2025/06/1290

13. C-2025/05/1289

14. C-2025/05/1288

15. C-2025/05/1285

16. C-2025/05/1284

17. C-2025/05/1282

18. C-2025/06/1296

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.