March 25, 2020

Mohit Kabra
Group Chief Financial Officer
MakeMyTrip Ltd
19th Floor, Building No. 5
DLF Cyber City
Gurugram, India, 122002

       Re: MakeMyTrip Ltd
           Form 20-F for Fiscal Year Ended March 31, 2019
           Filed July 23, 2019
           File No. 1-34837

Dear Mr. Kabra:

       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 Fiscal Year Ended March 31, 2019

Item 4. Information on the Company
Business Overview, page 37

1.    We note your disclosure of active users per month in fiscal year 2019 for
desktop and
      mobile websites and mobile applications. Revise your disclosures to
provide active users
      per month for each fiscal year period presented.
Item 5. Operating and Financial Review and Prospects
Certain Non-IFRS Measures, page 88

2.    We refer to your measure of Adjusted Revenue. Please provide us with the
following
      information with respect to the adjustments made to arrive at this
non-IFRS measure and
      the measure as a whole:
 Mohit Kabra
FirstName LastNameMohit Kabra
MakeMyTrip Ltd
Comapany2020
March 25, NameMakeMyTrip Ltd
March 25, 2020 Page 2
Page 2
FirstName LastName
              Tell us in detail what types of promotion expenses are included
in the first adjustment
              and how you determined the amount to include in the adjustment.
In addition,
              provide quantification for each material type of promotion
expense included in this
              adjustment.

              Tell us why "Service Cost as per IFRS" is deducted from revenue
to arrive at a non-
              IFRS measure of revenue. Note that Adjusted Revenue does not
appear to be a
              measure of revenue as it contemplates a non-revenue line item in
the calculation.

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

              Understanding that you believe that Adjusted Revenue reflects the
value addition of
              the travel services that you provide to your customers, explain
to us how this measure
              is used by management and why you believe the presentation of
this non-IFRS
              financial measure provides useful information to investors
regarding your financial
              condition and results of operations. Refer to Items
10(e)(1)(i)(C) and (D) of
              Regulation S-K.
Notes to the Consolidated Financial Statements
Note 7   Operating Segments, page F-36

3.       We note that you appear to present two segment metrics, Segment
Revenue and Segment
         Revenue less Service Cost. We further note your disclosure on page
F-27 which states:
         "For the purposes of the CODM review, the measure of segment revenue
(which includes
         adding back certain promotion expenses reported as a reduction of
revenue) as reduced by
         service cost is a key operating metric, which is sufficient to assess
performance and make
         resource allocation decisions." Please address the following:

              Confirm that your segment measure of profit or loss in accordance
with paragraph 23
              of IFRS 8 is Segment Revenue less Service Cost as indicated by
your disclosure on
              page F-27.

              Tell us whether Segment Revenue less Service Cost as presented in
your footnotes is
              consistent with the profit or loss measure that is received by
your CODM and that is
              used for purposes of making decisions about allocating resources
to the segment and
              assessing its performance.

              We note that Service Revenue less Service Cost excludes certain
promotion
              expenses. Tell us whether the data regarding these promotion
expenses is used
 Mohit Kabra
MakeMyTrip Ltd
March 25, 2020
Page 3
              separately by your CODM to make decisions about allocating
resources to the
              segment and assessing its performance.

              Describe any other financial data that is received by your CODM
and that is used for
              purposes of making decisions about allocating resources to the
segment and assessing
              its performance.
4.       We note that your information on reportable segments presents Segment
Revenue which
         excludes $358 million of promotion expenses for the year ended March
31, 2019 that are
         recorded as a reduction of revenue under IFRS. Provide us with your
basis in IFRS 8 to
         support presentation of this measure.
       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 Diane Fritz, Staff Accountant, at (202) 551-3331 or
Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 with any questions.



FirstName LastNameMohit Kabra                                Sincerely,
Comapany NameMakeMyTrip Ltd
                                                             Division of
Corporation Finance
March 25, 2020 Page 3                                        Office of Energy &
Transportation
FirstName LastName