Competition Monthly April 2026

Welcome to the April 2026 edition of Phoenix Legal’s Competition Monthly. This issue captures key developments in the antitrust and competition space during the last calendar month.

CCI DISMISSES ABUSE OF DOMINANCE ALLEGATIONS AGAINST BOOKMYSHOW IN ONLINE MOVIE TICKETING INTERMEDIATION MARKET

The Competition Commission of India (CCI), by its order dated 12 March 2026, closed the proceedings against Big Tree Entertainment Pvt. Ltd. (BookMyShow) finding no abuse of dominant position under the Competition Act, 2002 (Act).

The case arose from the information filed by Showtyme, alleging that BookMyShow engaged in anti-competitive conduct through exclusive agreements with cinemas, discriminatory revenue sharing, restrictive data practices, and denial of market access to rival platforms. The Director General (DG), upon investigation, had found BookMyShow to be dominant and indicated potential contraventions under Section 4.

During final adjudication, the CCI delineated the relevant market as the “market for online intermediation services for booking of movie tickets in India” and agreed with the DG that BookMyShow held a dominant position during the period under investigation, considering its significant market share, network effects, and strong industry integration.

However, the CCI disagreed with the DG on abuse of dominance. It held that seat reservation practices were operationally justified, particularly for theatres lacking real-time integration, and did not constitute unfair or discriminatory conditions. Data- sharing arrangements were also not found to be discriminatory, as multiplexes and single-screen cinemas were not similarly placed.

Further, the CCI found that variations in convenience fee sharing were commercially negotiated and based on multiple factors, and therefore not discriminatory. On exclusivity agreements, the CCI held that they did not lead to substantial foreclosure of the market, noting that a significant portion of the market remained contestable and alternative platforms continued to operate.

CCI CLOSES CASE AGAINST INDIGO AND AIR INDIA ON CANCELLATION CHARGES; NO PRIMA FACIE CASE OF ABUSE

The CCI, by its order dated 11 March 2026, closed proceedings against InterGlobe Aviation Limited (IndiGo) and Air India Limited, finding no prima facie contravention of Sections 3 or 4 of the Act.

The case arose from allegations that both these airlines imposed excessive cancellation charges and acted in concert, amounting to anti-competitive conduct and abuse of dominance. The CCI found no evidence of any agreement or collusion between the airlines and reiterated that collective dominance is not recognised under the Act.

On abuse of dominance, the CCI held that airlines offer different fare categories with disclosed cancellation terms, giving passengers a choice of refund flexibility. Such practices were found to be uniform and not unfair or discriminatory. The CCI further clarified that issues relating to contractual fairness or reasonableness of charges fall outside its jurisdiction. Accordingly, the matter was closed at the prima facie stage.

CCI CLOSES COMPLAINT AGAINST GOOGLE OVER PLAY STORE ACCOUNT TERMINATION

The CCI, by its order dated 24 March 2026, closed proceedings filed by M/s Zucol Solutions Private Limited (Informant) (engaged in the business of digital software development and mobile application services) against Google India Private Limited, finding no prima facie contravention of Sections 3 and 4 of the Act.

The case arose from allegations that Google had arbitrarily terminated its developer accounts on the Play Store, denied market access, and failed to provide adequate reasons or due process prior to the termination.

The CCI delineated the relevant market as the “market for app stores for Android OS in India”, and noted that Google prima-facie held a dominant position in this market. On merits, the CCI found no abuse. It observed that Google’s actions were in line with its publicly disclosed Play Store policies, including appeal mechanisms, which had already been examined and upheld in other cases. The CCI also noted that Google had reinstated the Informant’s primary account, thereby addressing the core grievance.

Importantly, the CCI highlighted material inconsistencies and suppression of facts by the Informant, including contradictory statements regarding the impugned application, failure to disclose reinstatement of the account, and incomplete submission of correspondence.

In view of the above, the CCI found no prima facie case of contravention of Section 4 of the Act.

SUPREME COURT DECLINES TO INTERFERE IN CCI v. GEEP INDUSTRIES; QUESTION OF LAW KEPT OPEN

The Supreme Court of India, by its order dated 09 March 2026, disposed of the Special Leave Petition filed by the CCI against Geep Industries (India) Private Limited, arising out of the judgment of the Delhi High Court dated 01 November 2025 in an LPA.

By the impugned judgment, the Division Bench            of   the   Delhi   High   Court   had dismissed the CCI’s appeal and upheld the setting aside of its retrospective levy of interest on penalties, holding that such interest could not be recovered in the absence of a mandatory demand notice under the applicable recovery regulations. Upon hearing the parties, the Supreme Court observed that, in the peculiar facts and circumstances of the case, it was not inclined to interfere with the impugned judgment. However, the Court clarified that the question of law concerning the CCI’s power to         levy                  interest on           penalties, including            with retrospective     application, has been kept open, to be agitated in an appropriate future proceeding.

Accordingly, the Special Leave Petition was disposed of without adjudication on merits.

CCI APPROVES CONTINUUM ENERGY’S ACQUISITION OF REMAINING STAKE IN CONTINUUM GREEN ENERGY HOLDINGS

The CCI, by its order, approved the proposed acquisition by Continuum Energy Pte. Ltd. (CEPL/ Acquirer) of 26% of equity shareholding of Continuum Green Energy Holdings Ltd. (Target).

The proposed combination involves the Acquirer, which already held 74% stake in the Target, acquiring the balance shareholding from the existing shareholder. The Acquirer and the Target are part of the Continuum Group, which is engaged in the renewable energy sector in India, including development, operation, and sale of wind and solar power.

For the purpose of competition assessment, the  CCI  examined  horizontal  overlaps between the parties in (i) the market for generation of power in India at a broader level (Power Generation Market) and (ii) the market for generation of power from renewable sources in India at a narrower level (Renewable Power Market). The CCI noted that there were no vertical or complementary linkages between the parties.

The CCI observed that the incremental market share resulting from the proposed combination was negligible (in the range of 0–5%) in both markets, and that these markets are characterised by the presence of several significant competitors. Accordingly, the CCI concluded that the proposed transaction would not alter the competitive landscape.

Accordingly the CCI concluded that the proposed combination was unlikely to cause an appreciable adverse effect on competition in India and approved the transaction.

CCI APPROVES IHC’S ACQUISITION OF STAKE IN AADHAR HOUSING FINANCE LIMITED

The CCI, by its order, approved the proposed acquisition by AXDI LDII SPV 1 LTD. (Acquirer) of 10.04% shareholding (on a fully diluted basis) in Aadhar Housing Finance Limited (Target).

The proposed combination involves the Acquirer, a special purpose vehicle, owned by funds ultimately controlled by International Holding Company PJSC (IHC), acquiring a minority stake in the Target from the existing shareholder. The Target is a listed housing finance company engaged in providing housing loans, loans against property, and insurance distribution services in India.

For the purpose of competition assessment, the CCI examined horizontal overlaps between the parties in the broader market for the provision of loans and lending services in India (Loans Market) and the distribution of insurance in India (Insurance Distribution Market). Within the Loans Market, the Parties overlap in the retail loans segment, and further, within the retail loans segment, in the sub-segments of home loans and loans against property in India. Within the Insurance Distribution Market, the Parties overlap in the segments of distribution of non-life/general insurance and life insurance in India.

With respect to vertical linkages, CCI observed that here is a vertical relationship as the Target is present in the Loans Market (upstream) and the affiliates of Acquirer/IHC are present in the market for distribution of loans in India (downstream).

The CCI observed that the combined market shares of the parties were minimal (in the range of 0–5%) across all relevant markets and segments. Further, the vertical linkage was not likely to result in any foreclosure concerns, given the limited market presence of the parties.

Accordingly, the CCI concluded that the proposed combination was unlikely to cause an appreciable adverse effect on competition in India and approved the transaction.

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.