By MM Sharma

Noting that Google is the largest provider of adtech services and operates across the entire supply chain, the Competition Commission of India (CCI) has ordered a probe into alleged abuse of dominance by the tech giant in the online display advertising services market, writes MM Sharma

What were the CCI orders on ADIF’s petition against Google

The Competition Commission of India (CCI) recently split the information filed by the Alliance of Digital India Foundation (ADIF) against Google into three separate cases. On August 1, 2025, the competition watchdog issued two orders related to two of these cases:

-Order under Section 26(1) of the Competition Act in Case No. 23(1) of 2024, where it directed an investigation into allegations concerning the online display advertising services market through its adtech stack. This case focuses on Google’s alleged abuse of dominance in the online display advertising services market through its adtech stack.

-Order u/s Section 26(2A), in Case No. 23 (2) of 2024 where it closed a case against Google regarding its online search advertising market and Google Ads policies.

-The third case, Case No. 26(3) of 2024, is still pending. This case is about the three specific allegations of abuse of dominance in the following related markets:

-Google leveraging its dominant position in the general search market to increase profits from online search advertising market by imposing unfair conditions (including pricing conditions).

-Google indulging in non-transparent ad review and ad redressal process under inconsistent Google policies.

-Google removing third-party cookies from websites under its ‘Privacy Sandbox’ in Chrome browser.

What is an adtech stack

An adtech stack is the chain of intermediaries and technologies that enable online display advertisements. Key intermediaries include the Publisher Ad Server (PAS), Supply Side Platform (SSP), Ad Exchange, Demand Side Platform (DSP), and Advertiser Ad Server (AAS). 

Google’s adtech stack includes GAM (SSP), AdX (Ad Exchange), and DV360/Google Ads (DSPs).

The Alliance of Digital India Foundation or ADIF represents a majority of stakeholders in the digital ecosystem and includes startups among its members. 

Online display advertising case 

ADIF made five specific allegations against Google:

-Self-preferencing by tying services: Google allegedly tied its DFP with its AdX into a single GAM function.

-Tying its SSP with Ad Exchange: Google is accused of tying its SSP (DV360) with its AdX.

-Linking YouTube ad inventory: ADIF claimed that access to YouTube’s ad inventory is exclusively linked to the use of its SSP, DV360.

-Anti-competitive auction practices: Allegations included “Dynamic Allocation,” “Last Look” advantages, and non-participation in “Header Bidding,” among others.

-Lack of transparency: ADIF alleged non-transparency in Google AdSense for Search and its fee structure.

Google denied these claims, stating publishers had a choice of alternatives and its policies were pro-competitive. It defended its exclusive YouTube policy by comparing it to similar practices by Meta and Amazon. It claimed its pricing structure was transparent.

What did CCI say

The CCI noted that Google is the largest provider of adtech services and operates across the entire supply chain. It found that all five of ADIF’s allegations were already part of an ongoing investigation in a previous “Publishers case”. Recognising that ADIF represents a majority of stakeholders, the CCI decided to club the new matter with the ongoing investigation and directed the Director General to investigate the relevant market and submit a consolidated report.

Online search advertising case

This case dealt with allegations of Google’s abuse of dominance in the online search advertising services market through its Google Ads policy.

ADIF made four specific allegations:

-Restriction on third-party technical support providers.

-Restriction on “Call Ads” on desktops and laptops.

-Non-transparency in Google Ads Policies and ad ranking.

-Allowing competitors to bid on registered trademarks as keywords.

Google responded that its policies on third-party tech support and call ads were to protect users from fraudulent ads. It cited the Vishal Gupta case, where the CCI had rejected challenges to these policies. It referenced the Matrimony.com case, where allegations against ad ranking and keyword bidding were found to be without merit.

Why CCI closed this case

The CCI invoked the recently introduced Section 26(2A) of the Competition Act, which allows it to close a case if the facts and issues have already been decided in a previous order. The CCI found that the issues raised by ADIF were “substantially the same” as those already decided in the Vishal Gupta and Matrimony.com cases. Since ADIF did not provide any new evidence, the CCI closed the case under Section 26(2A), following the principle of res judicata.

The writer is head – Competition Law & Policy, Vaish Associates, Advocates

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