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Combination thresholds and filing screen

M&A documents should include a CCI screening before signing and closing. Asset/turnover thresholds, de-minimis relief, deal-value threshold, control and ex

Finin2min summary

M&A documents should include a CCI screening before signing and closing. Asset/turnover thresholds, de-minimis relief, deal-value threshold, control and exemptions must be tested.

Source review date: 4 July 2026. Read with the official text and the facts of the transaction.

Legal anchors

  • Sections 5 and 6
  • Combination Rules and Regulations, 2024
  • 2024 threshold and exemption rules

How to analyse it

  1. Map parties, groups and target business.
  2. Calculate India and worldwide assets/turnover.
  3. Test deal value and substantial business operations in India.
  4. Assess exemptions and control changes.

Practical illustration

A global acquisition has a small Indian target but a high transaction value and substantial Indian users. De-minimis relief does not automatically answer the deal-value test.

What can go wrong?

  • Using only target revenue
  • Ignoring inter-connected steps
  • Signing without conditions precedent

Evidence pack

  • Group financials
  • Transaction documents
  • Valuation and consideration bridge
  • India business metrics

Decision workflow

  1. Freeze the facts and effective date.
  2. Identify the controlling Act, rule, notification, circular and jurisdictional overlay.
  3. Prepare a calculation or exposure note.
  4. Collect the evidence pack before filing, payment, signing or response.
  5. Record reviewer conclusion and assumptions.

Quick Q&A

Is the result automatic?

No. Map parties, groups and target business.

What is the most important control?

Assess exemptions and control changes.

What should be escalated?

Using only target revenue, especially where money, deadlines, enforcement, personal liability or irreversible transaction steps are involved.

Official source trail

Secondary commentary may help interpretation, but it is not the source of law.

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