November 4, 2024

Jervey Choon
Chief Executive Officer
TriUnity Business Services Ltd
BO1-A-09, Menara 2, KL Eco City, 3, Jalan Bangsar 59200
Kuala Lumpur, Malaysia

       Re: TriUnity Business Services Ltd
           Registration Statement on Form S-1
           Filed October 8, 2024
           File No. 333-282541
Dear Jervey Choon:

       We have reviewed your 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.

Registration Statement on Form S-1
Cover Page

1.     Please revise the registration statement cover page to disclose the
name, address,
       including zip code, and telephone number, including area code, of the
company's
       agent for service. Please refer to Form S-1 cover page instructions.
2.     The filing fee table and related disclosure required by Item 16.(c) of
Form S-1 should
       be included in a filing fee exhibit rather than on the registration
statement cover page
       of your filing. Please see Item 601(b)(107) of Regulation S-K.
3.     Please revise the prospectus cover page to include the date of the
prospectus. Refer to
       Item 501(b)(9) of Regulation S-K. In this regard, we note that you have
included such
       date after the table of contents rather than on the prospectus cover
page.
 November 4, 2024
Page 2
Prospectus Summary, page 1

4.     Please revise to acknowledge in your Prospectus Summary that you have
identified
       conditions and events that raise substantial doubt about your ability to
continue as a
       going concern and explain these conditions and events. Please also
revise to provide a
       risk factor discussing your ability to continue as a going concern. We
note the
       discussion of the substantial doubt as to your ability to continue as a
going concern
       reflected in the report of your independent registered public
accountant.
Risk Factors, page 4

5.     Include a risk factor alerting investors that as a company with a
reporting obligation
       under Section 15(d) of the Exchange Act, you will not be subject to the
proxy rules,
       Section 16 of the Exchange Act and certain of the tender offer rules.
Please make
       similar revisions to the disclosure under    Reports to Security Holders
   on page 22,
       and specify that you will file annual, quarterly and other required
Exchange Act
       reports.
6.     Include a risk factor alerting investors that the company currently has
one officer,
       director and employee for all company business and operations. Please
also address
       the large amount due to such officer and director.
Our principal executive offices are located in Malaysia and our Company has a
non-U.S.
resident Officer and Director, page 5

7.     We note that you disclose that there might be limits to the
enforceability of civil
       liability provisions of U.S. federal securities laws against the company
  s officers and
       directors, and company assets. Please more specifically revise your risk
factor
       discussion here to disclose an investor's ability:

             to effect service of process within the United States against any
of your non-U.S.
           resident officers or directors;

             to enforce U.S. court judgments based upon the civil liability
provisions of the
           U.S. federal securities laws against the company's officers and
directors;

             to enforce in a Malaysian court a U.S. court judgments based on
the civil liability
           provisions of the U.S. federal securities laws against the above
foreign persons;
           and

             to bring an original action in a Malaysian court to enforce
liabilities based upon
           the U.S. federal securities laws against the above foreign persons.
We are an "emerging growth company" under the JOBS Act of 2012, page 6

8.     Please revise your disclosure here and elsewhere as necessary to reflect
the current
       revenue threshold for remaining an emerging growth company (i.e., if
your revenues
       exceed $1.235 billion as compared to the $1 billion threshold currently
disclosed).
       Refer to Exchange Act Rule 12b-2.
 November 4, 2024
Page 3

Management's Discussion and Analysis, page 14

9.     Please remove the references to Section 27A of the Securities Act of
1933 and Section
       21E of the Exchange Act of 1934. The statutory safe harbor for
forward-looking
       statements provided by these sections does not apply to statements made
in
       connection with an initial public offering.
10.    We note your risk factor concerning inflation. Please clarify your MD&A
discussion
       as to the impact of inflation on your operations and results.
Global Human Resource Outsourcing Services Market Size, page 15

11.    The reference to "billions" in the first paragraph appears incorrect
based upon the
       following chart. Please revise as applicable.
Description of Business, page 16

12.    Please note that the disclosure regarding the company's current business
and
       operations should accurately describe the current company rather than
aspirational
       business activities. Please revise to provide a more detailed summary of
the
       company's current business and operations to include the steps you have
taken to date
       to become an operating company. Please revise to clarify, if true, that
the company
       has provided limited accounting, bookkeeping, human resources and
administrative
       support services to date. To the extent that you discuss future business
plans here,
       such as the company's intentions to provide payroll management, document
       management, expense management or training services, the discussions
should be
       balanced with a brief discussion on the time frame for implementing
these future
       plans, the steps involved, the associated costs, and any obstacles
involved before the
       company can commence the planned operations. Lastly, to the extent the
company
       has not provided any services to date (i.e. payroll management or
document
       management), please revise to clarify that fact.
Marketing Strategy, page 17

13.    We note your reference to your website. Please revise your disclosure to
make clear
       that your website, does not appear to be meaningfully functional. In
this regard, please
       disclose the timeline and costs for when the website will be functional.
Use of Proceeds, page 18

14.    You state that as of July 31, 2024, your sole officer and director Ms.
Jervey Choon
       advanced the company a total of $28,949. Please clarify whether you
intend to use a
       portion of the net proceeds to repay the loans; and, where applicable,
please revise to
       discuss the material terms of the loan and file related agreements as
exhibits to the
       registration statement. Refer to Instruction 4 of Item 504 of Regulation
S-K and Item
       601(b)(10) of Regulation S-K.
Exhibits to Registration Statement, page 28

15.    Please file as an exhibit a specimen stock certificate and any other
instruments
       defining the rights of shareholders. Refer to Item 601(b)(4) of
Regulation S-K.
 November 4, 2024
Page 4

Exhibits to Registration Statement
Consent of Independent Accounting Firm, page 28

16.    The report date listed in your auditor consent does not agree with the
report date of the
       audit opinion included in your financial statements. Please have your
auditor revise
       accordingly.
Report of Independent Registered Public Accounting Firm, page F-2

17.    Please have your auditors revise their report to state, if true, the
procedures and
       opinion are for the period from April 30, 2024 (date of inception) to
July 31, 2024
       regarding all financial statements other than the balance sheet.
General

18.    We note that this registration statement is substantially similar to
registration
       statements filed by Rocky Mountains Group Ltd. (i.e. a Form S-1; File
No. 333-
       281852) and Keemo Fashion Group Limited (i.e. a Form S-1; File No.
333-267967).
       In this regard, we note that each of the filings uses a similar
prospectus presentation
       and formatting, offers a similar number of shares (i.e. 8,000,000) at
the same offering
       price of $0.015 per share, and contains similar risk factors,
description of securities,
       use of proceeds, plan of distribution, etc. Additionally, we note that
each company
       retained the same auditor, i.e. JP Centurion & Partners PLT based out of
Kuala
       Lumpur, Malaysia. Please advise regarding the substantially similar
registration
       statements.
19.    We note that the attorney who has provided your legal opinion has
disclaimed that he
       prepared the registration statement. In this regard, Section 11 of the
Securities Act of
       1933 provides that any expert who helped prepare the registration
statement, e.g.
       accountants or lawyers, may be liable for any misrepresentation or
omission of
       material information in the registration statement. Please advise
regarding the person,
       attorney or service provider who prepared (or assisted in the
preparation of) the
       registration statement.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 November 4, 2024
Page 5

       Please contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any
other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services