Combination Registration No. C-2026/05/1424, MARS Equity Dragon Fund VCC (‘MARS’), Krazybee Services Limited (‘Krazybee’), and Finnovation Tech Solutions Private Limited (‘Finnovation’)

Proposed Transaction

MARS is managed by Mars Equity M.C. Pte. Ltd., a capital markets services licence holder in Singapore and a wholly owned subsidiary of MUFG Bank, Ltd. (‘MUFG’), which sits under Mitsubishi UFJ Financial Group, Inc. Krazybee is a non-deposit taking non-banking financial institution registered with the Reserve Bank of India and is classified as a middle layer investment and credit company, offering unsecured personal and business loans, loan against property, and two-wheeler loans. Finnovation acts as technology provider and sourcing partner for Krazybee and other co-lending partners. Together they are the non-banking financial company and the technology company behind the KreditBee app and are sister companies with mirror shareholding structures in which the MUFG group already holds shareholding.

MARS acquired 2.74% in each of Krazybee and Finnovation through a mix of primary subscription and secondary purchases from Alpine Opportunity Fund IV and Mirae Asset. The notice was filed on May 15, 2026, and followed six transaction documents executed between April 3 and May 4, 2026, and the CCI approved the transaction on June 30, 2026. Stakes of this size are ordinarily exempt as solely an investment; here the Order records that the acquisition comes with access to certain commercially sensitive information and an observer right, which is what takes it out of the exemption and into a filing.

The Order also records a contingency. Krazybee filed a petition before the National Company Law Tribunal, Bengaluru on September 18, 2025, for the amalgamation of Finnovation into Krazybee. The transaction documents contemplate that if the scheme is approved before closing, MARS will hold 2.74% in Krazybee alone and will receive no shareholding in Finnovation, since Finnovation will have ceased to exist.

CCI Findings

Horizontal Overlaps: Combined shares were in the [0-5]% band across lending, distribution, and UPI-based payment applications, other than two-wheeler loans at [5-10]%.

Vertical Overlaps: The CCI also identified a potential vertical relationship between the provision of loans and lending services upstream and their distribution downstream and found the combined presence insignificant there as well.