This year, the Competition regulatory landscape witnessed significant developments.
This roundup confers a comprehensive assessment of verdicts delivered predominantly under the merger control and anti-trust regime from January to December 2025 by the Competition Commission of India (CCI), the Supreme Court, the National Company Law Appellate Tribunal (NCLAT) and various High Courts.
Additionally, we take a look at legislative and policy initiatives and Part V provides with the conclusion and the way forward.
Part I of this roundup covers Sections 3 (anti-competitive agreements) and 4 (abuse of dominant position) of the Act.
Section 3 cases
PF Digital Media Services Ltd v. UFO Moviez India Ltd & Others: The CCI found vertical restraints, specifically exclusivity on content supply imposed upon cinema theatre owners through agreements, to be in contravention of Sections 3(4)(a), 3(4)(b) and 3(4)(d).
Pranav Gupta v. FPBAI: The Commission found that the publication of conversion rates for ten currencies by FPBAI, which were higher than usual bank/RBI rates and followed by its member booksellers/publishers, amounted to price fixation, violating Sections 3(3)(a) and 3(3)(b).
Section 4 cases
XYZ v. Microsoft Corporation: The informant alleged abuse of dominant position via bundling and tying its antivirus product within the Windows OS. The CCI delineated the first relevant market as the ‘market for licensable operating systems for desktops/laptops in India’ and found Microsoft prima facie dominant therein. However, finding an absence of compulsion or imposition, the Commission dismissed the case under Section 26(2), concluding that there was no contravention.
Kshitiz Arya, Purushottam Anand v. Google LLC: This case involved a settlement proposal under Section 48-A(3). The DG found that pre-installation of the entire Google applications (GTVS) under TADA imposed unfair conditions, violating Section 4(2)(a)(i) and 4(2)(d). Furthermore, the DG found Google abused its dominant position by tying the YouTube app with the Play Store, violating Section 4(2)(e). Google proposed a settlement, agreeing to make available a standalone licence to the Google Play Store and GPS for compatible Android smart TV devices sold in India.
Grasim Industries Ltd v. Asian Paints Ltd: The informant alleged that Asian Paints was offering additional discounts and incentives such as foreign travel to its dealers in exchange for exclusivity, arbitrarily imposing exclusivity and coercing dealers against stocking rival paints. The Commission found Asian Paints to be prima facie dominant and directed an investigation under Section 26(1). The Bombay High Court later held that the DG could continue the investigation.
Elite Pro Basketball Private Limited v. Basketball Federation of India: The CCI found the Basketball Federation of India (BFI) to be prima facie dominant in the relevant market. The BFI’s refusal to authorise events organized by third parties without providing a transparent policy constituted a prima facie refusal to deal and denial of market access, the Commission held.
Part II focuses on Section 5 (combinations) and its regulation under Section 6. Combinations include acquisitions, control changes, mergers, amalgamations and transactions exceeding ₹2,000 crore deal value. Transactions must be notified to the CCI under Section 6(2), failure of which incurs a penalty under Section 43-A.
Notable combination approvals under Section 31(1)
Ambuja Cements Limited (Adani Group) - Orient Cement Limited (CK Birla Group): Approved acquisition of 46.80% of Orient Cement, which includes a mandatory open offer.
Tata Electronics Private Limited - Pegatron Technology India Private Limited: Approved acquisition by TEPL of up to 80% of Pegatron India’s equity share capital in two tranches.
Bajaj Finserv Limited, Bajaj Holdings & Investment Limited, Jamnalal Sons Private Limited - Bajaj Allianz Insurance Companies: Approved the acquisition of 26% paid-up equity share capital each of Bajaj Allianz Life Insurance Company Limited and Bajaj Allianz General Insurance Company Limited.
Jaiprakash Associates Limited (JAL) Acquisitions (IBC Resolution): Multiple parties received approval for acquiring JAL under the Insolvency and Bankruptcy Code, 2016 (IBC), including Dalmia Cement (Bharat) Limited, Adani Enterprises Limited and Jindal Power Limited.
Section 43-A order
Goldman Sachs (India) Alternative Investment Management Private Limited: The Commission imposed a penalty of ₹40,00,000 for consummating a subscription to optionally convertible debentures in Biocon Biologics Limited without prior notification to the CCI.
Part III assesses significant judgments by the Supreme Court, High Courts and NCLAT.
Supreme Court cases
CCI v. Schott Glass India Pvt Ltd: The Court affirmed that an effects-based approach is essential, demanding concrete evidence of harm to competition or consumers before condemning any conduct. The Court noted that dominance itself is not unlawful, and objectively justified volume-based rebates that do not foreclose rivals cannot be treated as abusive. It also highlighted serious procedural flaws, including the denial of cross-examination of key witnesses, violating natural justice.
Independent Sugar Corporation Ltd (INSCO) v. AGI Greenpac Ltd & HNGIL: The Court ruled that prior CCI approval must be obtained before the Committee of Creditors grants approval for a resolution plan involving a combination, emphasising the mandatory nature and literal interpretation of the proviso to Section 31(4) of the IBC.
CCI v. Kerala Film Exhibitors Federation & Ors: The Court clarified that the Competition Act does not require a bifurcated process for determining liability and penalty. Penalty is part of a composite inquiry and does not require a separate notice once the DG report and oral hearing opportunity are provided, the Court held.
High Court cases
Jiostar India Private Limited v. CCI: The Kerala High Court affirmed that parallel enquiry or proceedings can continue under both the Act and the TRAI Act within their respective statutory domains.
United India Insurance Company Limited v. CCI: The Delhi High Court found the imposition or affirmation of liability to pay interest on monetary penalty under Regulation 5 of the 2011 Regulations to be unsustainable in law and quashed the related orders and demand notices.
NCLAT cases
WhatsApp LLC v. CCI: While affirming the CCI’s jurisdiction to scrutinise data-related conduct, the Tribunal partially allowed the appeal by setting aside the finding of leveraging dominance and quashing the five-year blanket ban on data sharing. The NCLAT upheld the findings of abuse under Sections 4(2)(a)(i) and 4(2)(c) and sustained the monetary penalty of ₹213.14 crore. The Tribunal later clarified that the remedial directions apply to user data collection and sharing for both advertising and non-advertising purposes.
Part IV highlights the progression in institutional framing, evidenced by the introduction of new regulations and policy frameworks.
Key regulations and policy initiatives
CCI (Determination of Cost of Production) Regulations, 2025: This framework calculates costs under Section 4, primarily utilising average variable cost as a proxy for marginal cost, though other cost concepts may be used.
CCI (Manner of Recovery of Monetary Penalty) Regulations, 2025: These provide a detailed framework for penalty recovery, specifying that defaulters are liable for simple interest at 1% per month on the outstanding amount. Recovery can involve attachment of property or involvement of the income tax authority.
Market Study on AI and Competition (2025): The CCI released a landmark study identifying risks in the AI development layer, particularly due to the widespread adoption of foundation models and APIs. Key concerns included algorithmic collusion (mimicking traditional collusion without human coordination), price discrimination and increased entry barriers. The study recommended self-audits, compliance frameworks and monitoring of pricing strategies to mitigate risks.
MCA’s Market Study on Big Tech (2025): The Ministry of Corporate Affairs initiated a study to assess quantitative and qualitative thresholds for identifying Systemically Significant Digital Enterprises (SSDEs) and Core Digital Services (CDS) under the draft Digital Competition Bill (DCB).
2025 witnessed a total of 49 total anti-trust orders and the approval of 103 combinations by the CCI, with growing institutional capacity to address complex market structures.
Looking ahead, 2026 is expected to see further consolidation of policy priorities and enforcement. To begin with, the CCI published a press release stating that it had taken cognizance of information filed against IndiGo in the context of the recent flight disruptions.
The Delhi High Court’s consideration of Apple Inc’s challenge to the global turnover-based penalty framework is expected to have substantial implications on penalty jurisprudence under the Act.
As is the much-anticipated DG report in the media and advertising cartel investigation.
From the policy perspective, we can expect coordination between sectoral regulators, as evidenced from the dialogue held on August, 28 2025 between the CCI and the Ministry of Electronics and Information Technology on the Digital Personal Data Protection Act, 2023 (DPDP).
The continuing application of the de-minimis exemption with an expiration after two years in 2026 is to be anticipated with a fresh notification.
There were a few shortcomings with regard to delay, accompanied with the withdrawal of the DCB. However, the coming year might see the revival of the same.
For more details on Competition Law Yearly Roundup 2025 (India) click here.
Deesha Sarmah is a final year LLB (Hons.) student at Amity University, Noida.
Kushagra Mahajan is a final year BA LLB (Hons.) student at National Law Institute University (NLIU), Bhopal.