July 3, 2024

Mohanraj Ramasamy
Chief Executive Officer
SRIVARU Holding Limited
2nd Floor, Regatta Office Park, West Bay Road
P.O. Box 10655
Grand Cayman, KY1-1006
Cayman Islands

       Re: SRIVARU Holding Limited
           Amendment No. 1 to Registration Statement on Form F-1
           Filed June 25, 2024
           File No. 333-279843
Dear Mohanraj Ramasamy:

     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. Unless we
note otherwise,
any references to prior comments are to comments in our June 10, 2024 letter.

Amendment No. 1 to Registration Statement on Form F-1
Executive and Director Compensation, page 80

1.     We note your revisions in response to prior comment 2 and reissue in
part. We note your
       disclosure that no compensation was paid    for the Company's last full
financial year since
       the period covered in this Registration Statement is the first
applicable period for such
       disclosure since the closing of the Business Combination.    We also
note that closing of
       the Business Combination occurred on December 8, 2023. Please revise to
clarify whether
       the period in your revised disclosure covers the full financial year for
the year ended
       March 31, 2024. Further, we note your disclosure that initial grants of
equity may have
       been granted to directors. Disclosure of compensation is required on an
individual basis
       unless individual disclosure is not required in the company   s home
country and is not
 July 3, 2024
Page 2

       otherwise publicly disclosed by the company. Please advise. Further, if
the initial grants
       of equity were granted in the form of stock options, please provide the
title and amount of
       securities covered by the options, the exercise price, the purchase
price (if any), and the
       expiration date of the options. Finally, we note that the filing
includes other footnotes that
       appear to be internal notes to update the disclosure as required. Please
review and revise
       the footnotes on pages 5, 6, 49, 76, and 80 to ensure that your
disclosure is complete and
       current.
Index to Financial Statements, page F-1

2.     Please update the financial statements and other financial information
in the filing,
       including, but not limited to, MD&A, to comply with Item 8.A.4 of Form
20-F.
       Please contact Jenny O'Shanick at 202-551-8005 or Erin Purnell at
202-551-3454 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing
cc:   Rajiv Khanna