December 16, 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
           Amendment No. 1 to Registration Statement on Form S-1
           Filed November 27, 2024
           File No. 333-282541
Dear Jervey Choon:

     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 November 4,
2024 letter.

Amendment No. 1 to Registration Statement on Form S-1
Going Concern, page 1

1.     Please revise to disclose the amount due to a director as disclosed on
page F-3.
Significant Financial Obligation to Our Officer and Director Could Impact
Financial Stability
and Flexibility, page 4

2.     We note your response to comment 6 and reissue in part. Please revise to
quantify
       the substantial outstanding amount owed to your director.
 December 16, 2024
Page 2
Exhibits to Registration Statement, page 28

3.     We note your response to comment 14 and reissue in part. Please advise
whether the
       related-party advance is memorialized in any written agreement. If so,
please file the
       related-party agreement as an exhibit to the registration statement.
Refer to Item
       601(b)(10) of Regulation S-K.
4.     We note your response to comment 15. Please explain to us why you do not
have a
       stock specimen at this time.
Consent of Independent Accounting Firm, page 28

5.     In your next amendment, please file an updated auditor consent dated
within 30
       days of the filing as an exhibit.

       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