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                            August 16, 2023

       Mohan Ananda
       Chief Executive Officer
       Innovative International Acquisition Corp.
       24681 La Plaza Ste 300
       Dana Point, CA 92629

                                                        Re: Innovative
International Acquisition Corp.
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed August 8,
2023
                                                            File No. 333-269627

       Dear Mohan Ananda:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our July
14, 2023 letter.

       Amendment No. 3 to Registration Statement on Form S-4

       Certain Unaudited Projected Financial Information, page 141

   1.                                                   We note your disclosure
that due to certain developments from the time of the signing of
                                                        the Merger Agreement
through June 30, 2023, Zoomcar management determined that the
                                                        initial financial
projections no longer represented management   s reasonable view on
                                                        Zoomcar   s future
financial performance and decided to obtain revised projections. Please
                                                        revise to provide more
detail describing these developments. In addition, we note your
                                                        disclosure that the
updated financial projections were not available to and, accordingly,
                                                        not considered by the
IOAC Board in connection with its initial approval of the Merger
                                                        Agreement. Please
revise to clarify whether the changed circumstances have altered the
                                                        IOAC Board's
consideration and decision to recommend the business combination.
 Mohan Ananda
Innovative International Acquisition Corp.
August 16, 2023
Page 2
Zoomcar Inc. Consolidated Balance Sheets, page F-48

2.    We note the changes made to your balance sheet in response to comment 6.
Please
      explain why the notes to your financial statements do not include the
disclosures outlined
      in ASC 250-10-50-7 with respect to the change in classification in your
balance sheet of
      your redeemable noncontrolling interest. Also, please explain why your
auditors did not
      dual date their audit report with respect to the correction of this
error.
       You may contact Abe Friedman at 202-551-8298 or Linda Cvrkel at
202-551-3813 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Donald Field at 202-551-3680 with any
other
questions.



                                                           Sincerely,
FirstName LastNameMohan Ananda
                                                        Division of Corporation
Finance
Comapany NameInnovative International Acquisition Corp.
                                                        Office of Trade &
Services
August 16, 2023 Page 2
cc:       Ari Edelman
FirstName LastName