In October 2022, India’s Competition Commission issued one of the most detailed antitrust orders in the history of Indian digital commerce. The 131-page document fined MakeMyTrip Rs 230 crore, approximately $26.1 million, for anti-competitive and abusive practices in its hotel business. It ordered the company to stop specific practices immediately. It expressed confidence that MakeMyTrip would implement the direction of the Commission in its true import and spirit.
MakeMyTrip said it had already voluntarily addressed the issues before the order was even finalised. It confirmed in subsequent annual reports that it had complied with the behavioural directions issued by the CCI.
Then it appealed the order.
Three and a half years later, the Morpheus Research short-seller report published on March 30, 2026 presents a body of evidence assembled from 103 industry interviews that reaches a single unambiguous conclusion. The practices the CCI ordered MakeMyTrip to stop in 2022 are still happening. They are happening on a daily basis. The hotels know it. The industry knows it. The competing OTAs know it. The only people who appear not to know it, according to Morpheus Research, are MakeMyTrip’s shareholders.
What the CCI Ordered MakeMyTrip to Stop
The central practice the CCI targeted was price parity. Under price parity, MakeMyTrip prohibited its hotel partners from selling rooms at prices lower than those listed on MakeMyTrip, whether on the hotel’s own website or through any competing platform. This guaranteed MakeMyTrip the best available pricing across the entire market, undercutting competition and locking hotels into a relationship where giving any platform or customer a better deal than MakeMyTrip was contractually forbidden.
The CCI ruled that MakeMyTrip’s dominant position in India’s OTA market, which Morpheus Research estimates at approximately 50 percent market share, made price parity not merely an aggressive commercial practice but an anti-competitive abuse of dominance. It ordered the practice stopped.
MakeMyTrip said it had stopped. It simultaneously appealed the ruling. The next hearing is scheduled for April 29, 2026.
What the Hotels Actually Said
Morpheus Research did not rely on inference or document analysis to reach its conclusion that price parity continues. It spoke directly to the hotels, the hotel associations, and the competing OTAs that are directly subject to the practice.
An employee at Suba Hotels, a 129-plus location chain across India, told Morpheus: “We have a parity clause in the contract where the OTA can go and match the rates. If another player gets aggressive for whatever reason MakeMyTrip might try and leverage you basically to say you must reduce your rate to be competitive.”
An employee at Pride Hotels, a 35-property chain listed on MakeMyTrip, was asked directly about price parity clauses in their current contract. The response was immediate: “It is always there. It is always there. Right.”
A former MakeMyTrip director described the daily operational reality: “On a daily basis. We do parity, first priority parity with other OTAs.”
Another former MakeMyTrip manager described the enforcement mechanism: “Once that parity score is met, let’s say I want 90 percent above parity, and I see that the hotel is converting but is not getting traffic, I will reach out to the hotel. Now, I have forecasted that once I get an exclusive rate from you, I will be able to increase this production.”
And a leader from the Federation of Hotel and Restaurant Associations of India, the industry body that was a key party in the original 2022 CCI case, told Morpheus with no ambiguity: “It is still there. They got away with it.”
The Rebranding That Fooled Nobody
One of the more sophisticated elements of Morpheus Research’s price parity allegation is the documentation of how MakeMyTrip appears to have continued the practice while changing its name to avoid the specific terminology the CCI order used.
An OYO executive explained the mechanism to Morpheus in detail. MakeMyTrip does not call it price parity anymore. It calls it a price competitiveness score. The score is embedded in MakeMyTrip’s ranking algorithm. A hotel that prices itself lower on a competing platform than on MakeMyTrip will see its ranking fall on MakeMyTrip’s search results without any explicit contractual price parity clause being invoked.
The OYO executive’s explanation of the effect was precise: “So even without any contractual obligation, if I am losing my ranking and business on MakeMyTrip, I then become by themselves obliged to give them the similar prices.”
The CCI’s 2022 order specifically addressed this practice, noting that MakeMyTrip threatened to reduce the visibility of properties that maintained pricing disparities with competitors. MakeMyTrip was ordered to stop. The OYO executive’s 2026 testimony to Morpheus suggests the mechanism is still operational, operating through an algorithm rather than a contract, which makes it harder to prove and equally effective at producing the same economic outcome.
The Deboosting Weapon
A ClearTrip executive gave Morpheus Research the most current and specific account of how MakeMyTrip enforces its pricing requirements in 2026. The executive described conversations happening in the week of the interview in which MakeMyTrip representatives were approaching hotels that listed on ClearTrip and giving them a choice: MakeMyTrip or ClearTrip.
Hotels that refused the ultimatum were being deboosted, meaning their visibility in MakeMyTrip search results was manually suppressed to the point where they would never surface in search results. The ClearTrip executive was explicit that nothing was being put in writing: “Obviously, they cannot go ahead and put this on paper, but this is what they are saying.”
The same executive explained the consequence for a hotel that chose ClearTrip over MakeMyTrip: “The hotel is never going to surface. Forget about in the top 10 or top 15. It is never going to surface. And the hotels will also not understand what is happening until a long time, and then they will just call up the market manager and say that you know what happened.”
The Money in the Bank Mechanism
Morpheus Research identifies the financial mechanism that enables MakeMyTrip to enforce price parity and exclusive inventory access without always requiring a formal contractual clause. It is called Money in the Bank, or MIB, a practice where MakeMyTrip makes large upfront cash deposits to hotels in exchange for guaranteed access to preferential pricing and peak-season inventory.
A former MakeMyTrip director described the two benefits of MIB with striking candour: “One is that we get exclusive buy rates that nobody else in the market gets, because we get 2 to 3 percent extra. Second is we get inventory guaranteed during peak season. New Year’s, Christmas, Diwali, long weekends, there is guaranteed inventory earmarked for MakeMyTrip without it being openly known, because these are monopolistic practices, so you cannot do that openly.”
Another former director described the financial pressure the MIB deposits place on hotel partners: “It is a proxy pre-purchase because the hotel partner is always in pressure because he has taken money.”
MakeMyTrip disclosed approximately $12 million in security deposits to hotels in its 2025 annual report. Former employees told Morpheus the true scale of MIB deposits covers up to 30 percent of domestic hotel partners and 15 to 18 percent of international partners, suggesting the disclosed figure significantly understates the actual programme.
The Investigation Nobody Knows About
The most significant revelation in Part 1 of the Morpheus report is not the continued price parity or the deboosting or the MIB programme. All of those are continuations of practices the CCI already identified and penalised in 2022.
The most significant revelation is that in March 2024, the CCI appears to have opened an entirely new and separate investigation into whether MakeMyTrip’s price parity agreements constitute a hub-and-spoke conspiracy. This is a cartel offence under Indian competition law, a categorically more serious allegation than the 2022 anti-competitive behaviour finding.
Morpheus Research found evidence of this investigation in a peer-reviewed paper published in the International Journal for Multidisciplinary Research, which noted that the Director General’s report on the investigation was expected in early 2026. The CCI’s own website confirms the existence of an investigation matching the case number cited in the paper, though without identifying the parties involved.
This investigation has not been disclosed to MakeMyTrip’s shareholders. It does not appear in analyst reports. It has not been mentioned on a single earnings call.
A leading Indian legal expert told Morpheus Research why the hub-and-spoke classification matters: “If it is true, it is serious for one reason. A hub-and-spoke conspiracy is looked at under the cartel offence under competition law. It is considered, it is deemed, to be unlawful. What the commission just needs to prove is that an agreement took place. It does not need to prove effects of that agreement.”
In January 2026, Trip.com’s share price crashed 22 percent after the Chinese government disclosed an antitrust probe into suspected abuse of dominant market position. That investigation was disclosed. MakeMyTrip’s alleged second investigation has not been.
The Fine That Has Not Been Paid
The original Rs 230 crore fine from 2022 has still not been paid in full. MakeMyTrip paid a 10 percent deposit when it filed its appeal and has not paid the remaining 90 percent while the appeal remains ongoing. A legal expert told Morpheus that interest accrues on the outstanding balance at 12 percent annually, meaning the total liability could now be as high as $34 million, equivalent to approximately 60 percent of MakeMyTrip’s entire calendar year 2025 net income.
MakeMyTrip has not made any provision for this liability in its accounts. The appeal hearing is scheduled for April 29, 2026. If MakeMyTrip loses, it faces an immediate cash outlay equivalent to the majority of a full year’s profit, from a fine it told the Commission it had voluntarily addressed before it was even issued.
The commission said it expected MakeMyTrip to implement its directions in their true import and spirit. The hotels say the practices never stopped. The former employees confirm they never stopped. A competing OTA executive documented them happening in the week of the interview. And a second investigation, potentially more serious than the first, is sitting undisclosed in a peer-reviewed paper that MakeMyTrip’s shareholders have not been told about.
All allegations in this article are sourced from the Morpheus Research short-seller report on MakeMyTrip published March 30, 2026. Morpheus Research holds a short position in MakeMyTrip shares and profits if the stock price declines. MakeMyTrip has not responded to the report at time of publication. Business Upturn has not independently verified the allegations. This article is for informational purposes only and does not constitute financial or investment advice.