Further, CCI assessed the role of ISMA and EMAI in facilitating collusions between the sugar mills through various meetings that were conducted with sugar mills at the time when tenders were released by PSU OMCs. It was noted by CCI that ISMA had attempted to conceal the fact of the meetings from CCI, and its officials failed to provide any justifiable reasons for organising such meetings. CCI further observed that the meetings also included Bajaj Hindusthaan (‘Bajaj’), the largest Ethanol manufacturer, even though Bajaj was not a member of ISMA. Moreover, officials of ISMA had been in constant touch with officials of sugar mill manufacturers. EMAI, on the other hand had also conducted meetings with its member sugar mills after the tenders had been released. Based on the above, CCI concluded that ISMA and EMAI had facilitated collusion in violation of Section 3(1), 3(3)(a) & 3(3)(b) and 3(1) & (3)(3)(a) of the Act, respectively.In light of the above, CCI imposed a penalty of approx. Rs 37 crore (approx. US$5 million) on the sugar mills, computed at 7% of their relevant turnover of the preceding three financial years and approx. Rs 50 lacs (approx. US$65,000 ) on ISMA and EMAI computed at 10% of their average receipts of the preceding three years.