Competition Law Reforms: How India Updated Its Competition Act

India significantly updated its competition law framework in 2023, changing how mergers are reviewed and how the Competition Commission of India can resolve investigations. This article explains what changed and how the reformed law has been applied in one of its most closely watched recent cases.

The Deal-Value Threshold Change

Among the most significant changes, the 2023 amendment introduced an entirely new trigger for mandatory merger notification based on deal value rather than solely on the merging companies’ asset size or turnover, the previous standard. According to Business Standard’s coverage of the implementation, the Ministry of Corporate Affairs notified a deal-value threshold of Rs 2,000 crore, effective from September 2024, meaning transactions exceeding this value now require Competition Commission of India notification and review regardless of the specific companies’ individual asset or turnover figures, a change specifically designed to capture significant acquisitions, including of smaller but strategically valuable technology or digital companies, that might otherwise have escaped the older asset-and-turnover-based threshold entirely.

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The New Settlement and Commitment Mechanism

The reform also introduced a settlement and commitment mechanism, allowing companies under Competition Commission investigation to propose specific behavioural or structural commitments to resolve competition concerns without necessarily proceeding through a full, prolonged investigation and formal penalty process, a mechanism designed to allow faster resolution of competition concerns in cases where a company is willing to voluntarily address the specific anti-competitive practices identified, reducing the overall time and resources both the Commission and the affected company need to spend on a fully litigated enforcement process.

Reduced Approval Timelines

Alongside these structural changes, the amendment also reduced the standard timelines within which the Competition Commission must complete its review of notified mergers and acquisitions, a change aimed at making India’s merger review process faster and more predictable for companies navigating transactions that require regulatory clearance, addressing a longstanding business-community criticism that merger review timelines had previously created uncertainty that could complicate deal planning and execution.

The Google Android TV Settlement Case

The reformed law’s new settlement mechanism received one of its highest-profile early applications in a case involving Google. According to coverage by Business Today and Medianama, Google agreed to pay Rs 20.24 crore to settle an antitrust case specifically concerning its Android TV practices, with the Competition Commission of India formally approving the settlement in April 2025, according to SCC Online’s coverage of the Commission’s decision, a resolution that allowed the underlying competition concerns about Google’s Android TV licensing practices to be addressed through the new settlement framework rather than a fully litigated, potentially years-long enforcement proceeding.

The Broader Big Tech Antitrust Context

This Android TV settlement sits within a considerably broader pattern of Competition Commission scrutiny of major technology companies’ practices in India, with a separate dispute specifically concerning Google’s Play Store practices continuing to work its way through the Supreme Court, according to Trilegal’s tracking of the Commission’s quarterly milestones, illustrating that even as the settlement mechanism has provided a faster resolution pathway for some cases, other major technology antitrust disputes have continued proceeding through the more traditional, fully litigated enforcement and appeal process.

The Industry and Business Reaction

Industry and legal commentary on the 2023 reforms has generally been favourable regarding the reduced review timelines and the new settlement mechanism specifically, with businesses broadly welcoming the added predictability and the option to resolve competition concerns faster without necessarily admitting full liability through a formal enforcement order, even as some competition law specialists have separately raised questions about whether the settlement mechanism’s faster resolution pathway might, in certain cases, result in less rigorous scrutiny of genuinely serious anti-competitive conduct compared to a fully litigated proceeding that establishes a more detailed, precedent-setting factual and legal record.

Why the Deal-Value Threshold Specifically Targets Tech Acquisitions

The new deal-value threshold’s specific design rationale deserves particular attention: technology and digital-economy acquisitions frequently involve companies with modest current revenue or asset bases but very high acquisition prices, reflecting their future growth potential or strategic value rather than their present-day financial scale, meaning the older asset-and-turnover-based threshold could allow exactly this kind of high-value but asset-light acquisition to escape mandatory competition review entirely, a specific regulatory gap the 2,000 crore deal-value trigger was explicitly designed to close.

Bottom Line

The 2023 Competition Act amendment introduced a Rs 2,000 crore deal-value merger notification threshold effective from September 2024, alongside a new settlement and commitment mechanism and reduced merger review timelines, reforms the Competition Commission of India applied prominently in its Rs 20.24 crore Android TV settlement with Google in April 2025, even as a separate Google Play Store antitrust dispute continues through the more traditional, fully litigated Supreme Court appeal process, illustrating how the reformed framework now offers companies genuinely different resolution pathways depending on the specific nature and severity of the competition concerns involved.

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Abhyudaya Verma