Volume-Based Discounts Don't Always Mean Anti-Competitive Conduct: Objective Justification and Functional Rebates Matter Under Section 4

SC held that Schott India's volume-based discount scheme did not constitute anti-competitive behavior. The Court found no evidence of discriminatory pricing, exclusionary practices, or market foreclosure. The functional rebate and long-term supply agreement were deemed objectively justified. Critically, the Court emphasized that an effects-based harm analysis is essential under Section 4 of the Competition Act. The investigation was procedurally flawed due to denial of cross-examination, rendering the Competition Commission's original order invalid. The Appellate Tribunal's decision was affirmed, and the complainant was ordered to pay Rs. 500,000 in costs. .....

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