Exhibit 8.2

	Loeb & Loeb LLP
	10100 Santa Monica Blvd.
	Suite 2200	Main	310.282.2000
	Los Angeles, CA 90067	Fax	310.282.2200

[                ], 2023

Airship AI Holdings, Inc.
12226 134th Court NE
Redmond, WA 98052
Attention: Victor Huang, Chief Executive Officer

Re: Registration Statement of BYTE Acquisition Corp.

Ladies and Gentlemen:

We have acted as United States counsel to Airship AI Holdings, Inc., a Washington company (“Airship AI”), in connection with the proposed Business Combination (as defined below) contemplated by a Merger Agreement dated as of June 27, 2023 (as may be further amended and supplemented, the “Merger Agreement”), by and among BYTE Acquisition Corp., a Cayman Islands exempted company (“BYTS”), BYTE Merger Sub, Inc., a Washington corporation and a direct, wholly-owned subsidiary of BYTS (“Merger Sub”), and Airship AI, which provides for, among other things, following the domestication of BYTS as a Delaware corporation (the “Domestication”), the merger of Merger Sub with and into Airship AI, with Airship AI surviving the Merger as a wholly owned subsidiary of BYTS (the “Merger”) (collectively, the “Business Combination”).

The Business Combination and certain other related transactions are described in the Registration Statement of BYTE Acquisition Corp. on Form S-4 under the Securities Act of 1933, as amended (the “Securities Act”), filed on September 11, 2023 (Registration Number 333-274464) as amended through the date hereof (the “Registration Statement”).

In rendering this opinion, we have reviewed the Registration Statement and have assumed with your approval the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as copies, and the completeness and accuracy of the documents reviewed by us. We have assumed with your approval and have not verified the accuracy of the factual matters and representations set forth in the Registration Statement.

Based on the foregoing and subject to the assumptions, limitations and qualifications stated in the Registration Statement and herein, we hereby confirm and adopt as our opinion the statements of United States federal income tax law on the date hereof as set forth in the Registration Statement under the caption “Material U.S. Federal Income Tax Considerations — U.S. Holders — Tax Consequences of the Merger to U.S. Holders of Airship Securities.”

Airship AI Holdings, Inc. [                ], 2023 Page 2

This opinion is based upon the existing provisions of the Internal Revenue Code of 1986, as amended, Treasury Regulations promulgated thereunder, published revenue rulings and procedures from the United States Internal Revenue Service (“IRS”) and judicial decisions, all as in effect on the date hereof. Any such authority is subject to change, and any change may be retroactive in effect and may affect our opinion as set forth herein. Our opinion is based on the facts, assumptions and representations set forth in the Registration Statement and this opinion. If any of the facts, assumptions or representations is not true, correct or complete, our opinion may not be applicable. We undertake no responsibility to update this opinion or to advise you of any developments or changes as a result of a change in legal authority, fact, representation, assumption or document, or any inaccuracy in any fact, representation or assumption, upon which this opinion is based, or otherwise.

Our opinion is not binding on the IRS or a court. The IRS may disagree with one or more of our conclusions, and a court may sustain the IRS’s position.

We hereby consent to the filing of this letter as an exhibit to the Registration Statement and to the reference to this firm as counsel to Airship AI under the caption “Material U.S. Federal Income Tax Considerations — U.S. Holders — Tax Consequences of the Merger to U.S. Holders of Airship Securities” in the Registration Statement, without implying or admitting that we are “experts” within the meaning of the Securities Act or the rules and regulations promulgated thereunder, with respect to any part of the Registration Statement, including this exhibit.

Regards,

Loeb & Loeb LLP