In A Significant First, CCI Denies Full Immunity To First-in Leniency Applicant

Introduction

1. On July 13, 2026, the Competition Commission of India (“CCI”), by way of two separate orders, imposed an aggregate penalty of approx. INR 138.98 crore (approx. USD 14.63 million [1] ) on HP India Sales Private Limited (“HP India”), in addition to nominal penalties on HP India’s network of resellers, for bid-rigging in Government e-Marketplace (“GeM”) tenders concerning: (i) the sale and supply of personal system products, such as laptops, desktops, workstations and related offerings such as monitors and keyboards (“Systems Case”) [2] ; and (ii) supplies products, such as ink, toner cartridges, and other graphic and digital manufacturing supplies used with print hardware products (“Supplies Case”) [3]