SEC Comment Letter for Yatra Online, Inc. (YTRA) (CIK 0001516899) (YTRA) — Mar 23, 2026
Yatra Online, Inc. (YTRA) (CIK 0001516899)
Date: March 23, 2026 · CIK: 0001516899 · Accession: 0000000000-26-002909
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-37968
Letter
Re: Yatra Online, Inc. Form 20-F for the fiscal year ended March 31, 2025 Filed July 31, 2025 File No. 001-37968 Dear Anuj Sethi:
March 23, 2026
Anuj Sethi Chief Financial Officer Yatra Online, Inc. Gulf Adiba, Plot No. 272 4th Floor, Udyog Vihar, Phase II Sector 20, Gurugram-122008 Haryana, India
We have limited our review of your filing to the financial statements and related disclosures and have the following comments.
Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for the fiscal year ended March 31, 2025 Item 5. Operating and Financial Review and Prospects Adjusted Margin %, page 88
1. You define the key operating metric Adjusted Margin % as Adjusted Margin as a percentage of Gross Bookings. You also disclose the term Net Revenue Margin % which appears to be calculated in the same manner as Adjusted Margin %. Please revise to replace Net Revenue Margin % with Adjusted Margin %. March 23, 2026 Page 2 Results from Operations, page 99
2. We refer to your discussions of Adjusted EBTIDA Profit on pages 99 and 101. When presenting a non-IFRS measure, you are required to present the most directly comparable IFRS measure with equal or greater prominence. Please revise these presentations to comply with Question 102.10 of the Corporation Finance Interpretations on Non-GAAP Financial Measures. Certain Non-IFRS Measures Reconciliation of Adjusted (Loss)/Profit, page 112
3. Tell us how your presentation complies with the requirement to separately provide income tax effects related to the pretax adjustments added to arrive at Adjusted (Loss)/Profit, as well as on Adjusted Basic and Diluted Loss Per Share. Refer to Question 102.11 of the Corporation Finance Interpretations on Non-GAAP Measures.
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.
Please contact Brian McAllister at 202-551-3341 or Kimberly Calder at 202-551-3701 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation
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<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> March 23, 2026 Anuj Sethi Chief 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, 2025 Filed July 31, 2025 File No. 001-37968 Dear Anuj Sethi: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20-F for the fiscal year ended March 31, 2025 Item 5. Operating and Financial Review and Prospects Adjusted Margin %, page 88 1. You define the key operating metric Adjusted Margin % as Adjusted Margin as a percentage of Gross Bookings. You also disclose the term Net Revenue Margin % which appears to be calculated in the same manner as Adjusted Margin %. Please revise to replace Net Revenue Margin % with Adjusted Margin %. March 23, 2026 Page 2 Results from Operations, page 99 2. We refer to your discussions of Adjusted EBTIDA Profit on pages 99 and 101. When presenting a non-IFRS measure, you are required to present the most directly comparable IFRS measure with equal or greater prominence. Please revise these presentations to comply with Question 102.10 of the Corporation Finance Interpretations on Non-GAAP Financial Measures. Certain Non-IFRS Measures Reconciliation of Adjusted (Loss)/Profit, page 112 3. Tell us how your presentation complies with the requirement to separately provide income tax effects related to the pretax adjustments added to arrive at Adjusted (Loss)/Profit, as well as on Adjusted Basic and Diluted Loss Per Share. Refer to Question 102.11 of the Corporation Finance Interpretations on Non-GAAP Measures. 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. Please contact Brian McAllister at 202-551-3341 or Kimberly Calder at 202-551-3701 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation </TEXT> </DOCUMENT>