July 19, 2024

Weihong Du
Chief Executive Officer
Transit Pro Tech Inc.
100 N. Barranca Street, Suite 460
Covina, CA 91791

       Re: Transit Pro Tech Inc.
           Registration Statement on Form 10-12G
           Filed July 1, 2024
           File No. 000-56650
Dear Weihong Du:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response and any amendment you may file in response
to this letter,
we may have additional comments.

Registration Statement on Form 10-12G
Item 1. Business
Sales and Marketing, page 5

1.     We note your disclosure that "[M]uch of our intellectual property,
including patents filed
       in the United States, will be owned by TP Hong Kong" rather than being
owned by
       Transit Pro Delaware. Please revise to provide a more complete
discussion regarding the
       risks associated with your Hong Kong subsidiary owning your intellectual
property.
Item 4. Security Ownership of Certain Beneficial Owners and Management, page 40

2.     We note your references to the irrevocable proxy granted to Mr. Du to
vote or otherwise
       act with respect to all outstanding Class B Common Stock. Given those
voting
       agreements, please add a column to the beneficial ownership table to
reflect the aggregate
       voting power granted to Mr. Du that includes the combined voting power
with the
       irrevocable proxies.
 July 19, 2024
Page 2
General

3.     We note your disclosure that you will transfer any dividends to TP Hong
Kong in
       accordance with the laws and regulations of the PRC, and then TP Hong
Kong will
       transfer the dividends to Transit Pro Delaware. Please revise as
appropriate to clarify that
       the risks applicable to PRC companies are also applicable to your Hong
Kong subsidiary,
       specifically as it relates to the transfer of cash and issuance of
dividends.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Matthew Derby at
202-551-3334
with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   Vincent McGill