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
Anuj Kumar Sethi
FirstName LastNameAnuj Kumar Sethi
Yatra Online, Inc.
Comapany
June NameYatra Online, Inc.
23, 2023
June 23,
Page 2 2023 Page 2
FirstName LastName
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).
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.
FirstName LastNameAnuj Kumar Sethi Sincerely,
Comapany NameYatra Online, Inc.
Division of Corporation
Finance
June 23, 2023 Page 3 Office of Energy &
Transportation
FirstName LastName