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                              August 17, 2023

       Lau Chi Fung
       Chief Executive Officer
       CTRL Group Limited
       Unit F, 12/F, Kaiser Estate Phase 1,
       41 Man Yue Street, Hunghom,
       Kowloon, Hong Kong

                                                        Re: CTRL Group Limited
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted July 31,
2023
                                                            CIK No. 0001969928

       Dear Lau Chi Fung:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 2 to Draft Registration Statement on Form F-1 submitted
July 31, 2023

       Risk Factor, page 13

   1.                                                   We note your response
to comment 7 and reissue. You revise to define "recurring clients"
                                                        on page 14 as "any
current clients and clients with which [you] have previously done
                                                        business." Please
revise to clarify the underlying assumptions, including limitations on the
                                                        time period used to
identify recurring clients, if any.
       Capitalization, page 41

   2.                                                   We note your response
to our prior comment number 9. Please also revise to present pro
                                                        forma EPS for the
latest fiscal year and any subsequent interim period presented in your
 Lau Chi Fung
CTRL Group Limited
August 17, 2023
Page 2
      financial statements reflecting dilution equivalent to the number of
shares whose proceeds
      will be used to pay the HK$ 8,000,000 of dividends declared on May 2,
2023.
3.    We note the revisions to your capitalization disclosures in response to
comment 9. It
      appears that your pro forma disclosures only give effect to the HK$
3,000,000 dividend
      declared on May 2, 2023 and do not include the HK$ 5,000,000 dividend
that was also
      declared on this date. Please revise your pro forma capitalization
disclosures to also
      include the effect of the HK$ 5,000,000 dividend declared on May 2, 2023.
Also, please
      provide footnote disclosure explaining how you calculated the US dollar
amounts
      disclosed in your pro forma capitalization disclosures.
Index to Consolidated Financial Statements, page F-1

4.    Please amend to provide updated audited financial statements for the
fiscal year ended
      March 31, 2023.
       You may contact Aamira Chaudhry at 202-551-3389 or Linda Cvrkel at
202-551-3813 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennie Beysolow at 202-551-8108 or Jennifer Lopez Molina at
202-551-3792 with any
other questions.



                                                           Sincerely,
FirstName LastNameLau Chi Fung
                                                           Division of
Corporation Finance
Comapany NameCTRL Group Limited
                                                           Office of Trade &
Services
August 17, 2023 Page 2
cc:       Eric Mendelson, Esq.
FirstName LastName