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March 15, 2023
Anuj Kumar Sethi
Principal Financial Officer
Yatra Online, Inc.
Gulf Adiba, Plot No. 272
4th Floor, Udyog Vihar, Phase-II
Sector-20, Gurugram - 122008
Haryana , India
Re:Yatra Online, Inc.
Form 20-F for the Fiscal Year Ended March 31, 2022
Filed August 1, 2022
File No. 001-37968
Dear Anuj Kumar Sethi:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2022
Certain Non-IFRS Measures, page 115
1.We note you present the non-GAAP measure, Adjusted Revenue, for each of your
segments and in total and that it is derived by adding customer promotional expenses to
revenue and subtracting service cost related to your Hotels and Packages Segment.  Please
address the following points:

•As it appears the adjustments to calculate Adjusted Revenue have the effect of
presenting revenue on a basis other than IFRS, tell us how you considered Question
100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations and concluded that Adjusted Revenue does not substitute individually
tailored revenue recognition and measurement methods for those of IFRS;

 FirstName LastNameAnuj Kumar Sethi
 Comapany NameYatra Online, Inc.
 March 15, 2023 Page 2
 FirstName LastName
Anuj Kumar Sethi
Yatra Online, Inc.
March 15, 2023
Page 2

•Tell us why service cost is deducted from revenue to arrive at a non-IFRS measure of
revenue.  In this regard, we note that Adjusted Revenue does not appear to be a
measure of revenue as it contemplates a non-revenue line item in the calculation.
Notes to the Consolidated Financial Statements
5. Segment Information, page F-28
2.We note you disclose “segment revenue” for the purpose of presenting your “segment
results”, which appears to be your measure of segment profit or loss under IFRS 8.  Please
address the following points:

•Confirm that segment results is your measure of segment profit or loss;

•Provide us your basis under IFRS 8 to support your presentation of segment revenue.
In this regard, we note that in determining segment revenue, you exclude promotional
expenses that are recorded as a reduction of revenue under IFRS15.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Joanna Lam at 202-551-3476 or Steve Lo at 202-551-3394 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation