Thread by @MorpheusRes

NEW REPORT: MakeMyTrip (NASDAQ: MMYT)

MakeMyTrip – How India’s Largest Travel Platform Openly Defies Regulators, Scams Customers, And Pads Profits Through Accounting Tricks

$MMYT

(1/x)morpheus-research.com/makemytrip

$MMYT is a $3.5 billion online travel agency (“OTA”) that is sometimes referred to as the “Booking(.)com of India” with 50% of the Indian OTA market, and 43% of its margins generated from selling hotel room nights. Most of its business is conducted through its apps.

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Our investigation, incl. 103 interviews, reveals that $MMYT is engaged in anti-competitive practices despite a significant penalty & stop order from antitrust regulator (CCI) in 2022. We also found a NEW & undisclosed CCI investigation, with a report due in “early 2026.”

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Further, $MMYT appears to be padding profits through accounting tricks, downplaying competition as it quietly loses market share, misleading customers through manipulative dark patterns, and by allowing “bad actor” hotels to proliferate on its platform.

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In Oct 2022, $MMYT was fined ~$26m by the CCI for “anti-competitive” & “abusive” practices. After claiming it “voluntarily” addressed the issues, we found evidence that $MMYT is openly defying the regulator’s order.

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One abusive practice that the CCI ordered $MMYT to stop was “price parity,” whereby $MMYT prohibited hotels from selling rooms at prices lower than the prices on $MMYT. Per the CCI, the “dominant position” of $MMYT exacerbated the “anti-competitive” impact of this practice.

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In Aug 2025, Indian media reported that $MMYT price parity still existed based on a publicly-accessible hotel contract available on the website of a $MMYT subsidiary. 2 days after the report, the web page became inaccessible, per internet archives.

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Hotel executives and former $MMYT employees confirmed to us that price parity is still widely in force, with enforcement occurring on a “daily basis” and with hotel partners receiving a “parity score.”

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We interviewed management from two mid-sized hotel chains, Pride Hotels and Suba Hotels, collectively representing ~164 hotels, who told us that price parity is a part of their contracts with MakeMyTrip.

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We interviewed a leader from Indian hotel association FHRAI, which was a key party in the CCI’s 2022 case against $MMYT. The FHRAI leader told us that price parity is “still there” and that $MMYT “got away with it” by ignoring the regulators.

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Several industry experts confirmed an indirect enforcement tactic previously identified in the CCI order. For example, an employee from a hotel partner, OYO, told us they could lose their “ranking and business on MakeMyTrip” if they do not comply with price parity.

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A former $MMYT employee told us that if a hotel was slow to respond to its demand for price parity, $MMYT “may just go and match the rates” without the hotel's permission.

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An exec from a competitor, ClearTrip, said that $MMYT is “going to our top sellers” and “deboosting” the ones who are “saying no” to $MMYT’s demands. The exec explained that $MMYT can ensure a “hotel is never going to surface” on its website if it doesn’t get its way.

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Price parity appears enabled by what one former executive described as “money in the bank” (MIB) where $MMYT places large upfront deposits with hotels to get “rates that nobody else in the market gets” and “inventory guaranteed during peak season.”

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In March 2024, the CCI appears to have launched a new investigation into more serious “hub-and-spoke” anti-competitive behavior at $MMYT with a report “expected in early 2026,” per a peer-reviewed paper. This investigation has not been disclosed to shareholders.

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We asked a legal expert familiar with the 2022 CCI Order about this new investigation: “If it’s true, it is serious for one reason: a hub-and-spoke conspiracy is looked at under the Cartel Offense under competition law. It is considered, it is deemed, to be unlawful …”

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Accounting Red Flag #1: After the ~$26m fine by the CCI in 2022, $MMYT was permitted to pay a 10% deposit while its appeal was reviewed. A legal expert familiar with the case told us the remaining sum accrues 12% annual interest, meaning the balance could be as high as ~$34m.

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$MMYT has failed to make any provision at all for a negative outcome of its appeal of the CCI case, which could incinerate up to 60% of its calendar 2025 net income.

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Accounting Red Flag #2: $MMYT has a $20m receivable from Go Air, a now insolvent airline that competing OTAs have completely written off. $MMYT has provisioned for just half of the balance, with the remainder representing customer deposits for bookings through $MMYT.

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Exposing itself to a similar situation as Go Air, $MMYT has extended advances to stressed startup airline Akasa, per a former $MMYT executive. Akasa reported a $210m loss in 2025 while enduring high-level executive departures recently, per local media.

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Accounting Red Flag #3: $MMYT uses “adjusted” metrics that differ from economic reality, e.g. “adjusted margin,” which nonsensically adds back customer acquisition costs, enabling it to claim expanding margins in air ticketing when IFRS margins are shrinking.

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$MMYT adjustments dwarf those of peers, Expedia and Booking. Since Dec-21, $MMYT “adjustments” have represented 76% of its total quarterly adjusted profit, while peers Booking and Expedia’s adjustments typically represent only 11% and 18% of adjusted metrics, respectively.

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To provide a partial exit to strategic investor Trip[.]com, $MMYT issued 0% convertible notes w/conversion price 3x from current levels. Holders have the option to force repurchase of their notes 2 yrs before maturity. This may result in a major cash outlay of $1.4 bn in 2028.

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In July 2025, CEO Rajesh Magow said that $MMYT only “theoretically” competes and that “there is no real other OTA player” in India. We believe $MMYT is downplaying competition. For example, execs from Booking publicly stated last year that “all eyes are on India.”

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Former $MMYT execs and employees told us $MMYT has been “blindsided” by Booking and its subsidiary Agoda, which has caused a “price war” that has driven down $MMYT hotel commissions from ~35% to as low as ~18%.

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MakeMyTrip’s OTA share with Marriott Hotels has decreased from 38% in 2022 to 31% today, while Booking’s share with Marriott has grown, according to an industry consultant.

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Meanwhile, an executive from hospitality chain OYO told us they have seen a 200-300% increase from Booking-owned Agoda, while MakeMyTrip’s business has declined 10-12% over the last 2 years.

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In the most recent quarter, $MMYT blamed its declining air ticket revenue on a flight scheduling crisis from leading Indian airline, IndiGo. Our research indicates that MakeMyTrip is simply losing share to competing OTAs and direct booking platforms.

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For example, Air India is doing more business with ClearTrip, a competing OTA, while MakeMyTrip’s share of OTA business has declined “between 2% to 5%” year-over-year, according to an executive from the airline.

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The Air India exec also mentioned Air India’s direct “one-click” AI booking platform, which public reporting indicates is directly aimed at reducing reliance on MakeMyTrip and other OTAs to avoid “significant commissions.”

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We found MakeMyTrip’s strategic partner & OTA, Trip[.]com, is entering the Indian market directly & hiring for key roles in India, furthering the likelihood of an exit from its remaining 16% stake. Notably, Trip[.]com founder James Liang filed to sell $3m of $MMYT last month.

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$MMYT fails to protect customers from “bad actor” hotels that proliferate across its platform. We aggregated reviews of 3,679 hotels & found that, in nearly 10% of properties, travelers reported incidences of serious women’s safety issues, extortion, or other shady practices.

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$MMYT appears to take little action and has failed to delist these properties, according to a former employee who explained that hotels are rarely banned from the platform.

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In Jan. 2026, $MMYT unveiled its AI-powered “women-focused safety & assurance features” aimed at enhancing “confidence and decision-making.” We found 113 hotels across 3 metro cities where reviews specifically highlight women’s safety issues. The hotels remain listed on $MMYT.

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In one recent example, a couple found a camera hidden in a flower vase facing their bed. After the hotel refused to refund them, the couple reported the incident to $MMYT, which offered a 25% discount while continuing to list the property.

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In another example, female travelers reported feeling unsafe at a hotel due to threats from drunk staff and male employees coming to their rooms at 3 am, writing that the hotel was “completely unsafe” for “family and girls.” The hotel is still listed on MakeMyTrip.

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We also found hundreds of examples of hotels extorting customers for more money at check-in, including one Bangalore hotel where 16 separate reviews describe aggressive extortion at check-in. This hotel is still listed on MakeMyTrip.

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State tourism authorities, like the State of Goa, require OTAs to only list registered properties. Yet $MMYT continues to allow unregistered properties onto its platform, according to a member of hotel association FHRAI and our own firsthand attempts to request registration numbers from various hotels.

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The Indian government has recently scrutinized dark patterns – the use of deceptive user interface designs aimed at “tricking” consumers into purchases – prompting $MMYT to voluntarily “self-declare” to regulators that its platform is free of manipulative dark patterns.

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Despite its declaration, $MMYT utilizes a series of dark patterns. While peers like Booking have designed their interfaces for “no hidden fees,” $MMYT uses “drip pricing” to mislead customers about total costs, including “convenience fees,” until the final check-out page.

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$MMYT uses pressure tactics and false claims to induce customers to buy unnecessary add-ons such as insurance, which it claims is “mandatory.” We highlight multiple examples from social media of $MMYT seemingly attempting to trick customers into buying trip insurance.

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In a similar example, $MMYT sends messages to customers claiming it already booked a cab for them when the customers never requested or booked a cab. In this way, $MMYT attempts to trick travelers into using its preferred car booking partners.

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$MMYT train biz pushes an insurance add-on called “Alternate Trip” which ostensibly offers a “3X Refund” if a ticket isn’t confirmed. Restrictions in the fine print render the add-on virtually worthless. Claims that “Alternate Trip” is a “scam” are rampant on social media.

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$MMYT has faced a flurry of legal cases, scathing reviews, and social media backlash related to its opaque refund procedures. An AI summary of 1700+ reviews reveals "considerable problems with refunds” including “long delays” and “outright denial” of funds.

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Even ignoring the findings of our investigation, $MMYT is the most richly valued OTA versus global peers on a forward P/E basis, trading at 18x forward earnings estimates,~40% higher than the 13x avg. of its peer group.

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Overall, we believe $MMYT is faltering under competitive pressure while trying to maintain the perception of its dominance through abusive and anti-competitive practices, aggressive accounting, and the increasingly deceptive extraction of value from its customers.

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After extensive research, we believe the evidence justifies a short position in shares of MakeMyTrip (NASDAQ:MMYT). Morpheus Research holds short positions in $MMYT. Full report and disclaimer available here.

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