September 26, 2024

Ivy Lee
Chief Financial Officer
SAG Holdings Ltd
14 Ang Mo Kio Street 63
Singapore 569116

       Re: SAG Holdings Ltd
           Amendment No. 20 to Registration Statement on Form F-1
           Filed September 20, 2024
           File No. 333-267771
Dear Ivy Lee:

     We have reviewed your amended registration statement and have the
following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Amendment No. 20 to Registration Statement on Form F-1
General

1.     Please refer to Exhibit 5.1. Please have company counsel revise the
legal opinion to cover
       the registered public offering and resale offering. In this regard, we
note that most recent
       legal opinion dated June 14, 2023 is dated and doesn't cover the current
offerings and
       specifically the resale offerings. Please revise as applicable.
 September 26, 2024
Page 2

       Please contact Scott Anderegg at 202-551-3342 or Donald Field at
202-551-3680 with
any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services