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United States securities and exchange commission logo
June 23, 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
Response dated April 5, 2023
File No. 001-37968
Dear Anuj Kumar Sethi:
            We have reviewed your April 5, 2023 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
March 15, 2023 letter.
Form 20-F for the Fiscal Year Ended March 31, 2022
Certain Non-IFRS Measures, page 115
1.We note your response to prior comment 1 explains that your presentation of the non-
IFRS measure Adjusted Revenue deducts amounts reflected in your statement of profit or
loss as service cost as if you acted as an agent in transactions when gross presentation is
required because you were the primary obligor. We also note that Adjusted Revenue adds
back customer promotional expenses which are reported in your financial statements as a
reduction of revenue. Please provide us with additional detail explaining how you
considered Question 100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations as Adjusted Revenue appears to substitute individually tailored

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Yatra Online, Inc.
June 23, 2023
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revenue recognition and measurement methods for those of IFRS or revise your disclosure
to remove this measure.
2.Please confirm that Adjusted Revenue as disclosed for your reportable segments is the
same as the measure Segment Results presented in your segment footnote and explain
why these measures have different titles. In addition, as it relates to the presentation of
segment profitability information outside of the footnotes to the financial statements, tell
us how you considered Questions 104.01 and 104.02 of the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations.
Notes to the Consolidated Financial Statements
5. Segment Information, page F-28
3.We note your response to prior comment 2.  It is unclear how your presentation of
“segment revenue,” which excludes amounts reported as reduction of revenue under IFRS
15, is consistent with IFRS 8 paragraph 23(a), which requires disclosure of “revenues
from external customers.”  Please explain or revise your segment footnote to instead
disclose “revenues from external customers” as required by IFRS 8.23(a).
4.In your response to prior comment 2, you state that you have three reportable segments:
air ticketing, hotels and packages, and other services.  However, in your Information about
Reportable Segments reconciliation, you also present segment results for “Others”.  Tell
us if “Others” is comprised of operating segments that meet the criteria in IFRS 8
paragraph 14.  If this criteria is not met for “Others”, revise your presentation to be
consistent with IFRS 8 paragraph 16.
5.We note that your reportable segments’ measures of profit or loss is titled “Segment
Results”.  This title appears similar to “Results from Operations” as presented in your
consolidated financial statements.  Please revise to clearly distinguish the measures.
6.Your Information about Reportable Segments reconciliation includes a line item for
unallocated expenses, which appears to be the sum of multiple types of expenses.  Please
disaggregate the unallocated expenses line item to separately identify and describe all
material reconciling items.  Refer to IFRS 8 paragraph 28.
7.We note your presentation of the subtotal “Operating loss (before depreciation,
amortization, impairment of goodwill and impairment of loan to joint venture)” in your
Information about Reportable Segments reconciliation table.  Please remove this non-
IFRS measure from your segment reconciliation. Refer to IFRS 8 paragraph 28(b).

 FirstName LastNameAnuj Kumar Sethi
 Comapany NameYatra Online, Inc.
 June 23, 2023 Page 3
 FirstName LastName
Anuj Kumar Sethi
Yatra Online, Inc.
June 23, 2023
Page 3
            You may contact Joanna Lam, Staff Accountant, at 202-551-3476 or Steve Lo, Staff
Accountant, at 202-551-3394 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation