Competition Law Newsletter – April 2025

March was a busy month for the Competition Commission of India (CCI / Commission) with a raid, a gun jumping order, several enforcement orders, and the National Company Law Appellate Tribunal (NCLAT) chipped in with its second Google judgment as well. We cover some of the most significant enforcement and combination orders published by the CCI.

NCLAT CONFIRMS AND OVERTURNS CCI PENALTY ON GOOGLE IN BILLING SYSTEM CASE

In October 2022 the CCI had found Google guilty of abusing its dominant position in relation to mandatory payments through Google Play Billing System (GPBS).

On appeal, the NCLAT vide Judgment dated 28 March 2025, upheld the findings of the CCI in relation to the relevant market and dominance but reemphasized the need of employing an effect-based analysis to ascertain any abusive conduct by a dominant enterprise. The NCLAT, relied on its previous ruling in Google case and the European Court of Justice and noted that a broad connotation shall