September 30, 2024

Ngo Chiu Lam
Chief Executive Officer
Skyline Builders Group Holding Limited
Office A, 15/F, Tower A, Capital Tower
No. 38 Wai Yip Street
Kowloon Bay
Hong Kong

       Re: Skyline Builders Group Holding Limited
           Amended Draft Registration Statement on Form F-1
           Submitted September 16 and September 23, 2024
           CIK No. 0002031009
Dear Ngo Chiu Lam:

     We have reviewed your amended draft registration statement and have the
following
comments.

        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 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 the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
September 5, 2024 letter.

Amended Draft Registration Statement on Form F-1
Management's Discussion and Analysis...
Liquidity and Capital Resources, page 61

1.     We note your revised disclosure in this section in response to prior
comment 4; however,
       the maturity dates for much of your debt as disclosed including in the
table starting on
       page 61 and in your disclosure on page 63 appear to have passed. We
note, for example,
       your disclosure that you re-drew from your revolving loan facilities,
resulting in an
       outstanding balance of US$6,358,678 as of July 31, 2024. Please revise
your disclosure
       throughout this section to clarify the current status of your
indebtedness.
 September 30, 2024
Page 2

Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-13

2.     We note your response to prior comment 7. Please further expand your
disclosures to
       state when you expect to recognize revenues related to unsatisfied (or
partially
       unsatisfied) performance obligations. Refer to ASC 606-10-50-13(b).
17. Segment Reporting, page F-33

3.     We note your response to prior comment 12 that the Company operates in a
single
       segment that represents its core business as an Approved Public Works
Contractor
       involving integrated services such as site formation, reinforced
concrete works, and
       drainage, which are components of comprehensive contracts rather than
distinct products
       or services. Please further clarify for us whether the Company is
providing only road and
       drainage work in its contracts whereby the construction activities you
disclose as
       undertaken by the Company on page 76 such as site formation works,
reinforced concrete
       structure works, road and drainage works, earthworks and landscape works
are integrated
       into the final deliverable or whether the Company also engages
specifically in providing
       contracts related to site formation, drainage and reinforced concrete
projects separately as
       the final deliverable. In that regard, we note the disclosure on page 73
related to the
       overview of civil engineering works in Hong Kong which seems to view
road and
       drainage work and site formation as separate segments in the civil
engineering
       works industry. It also appears there are sub categories such as
construction and
       maintenance for some of these categories. We remind you that the
disclosure
       requirements in ASC 280-10-50-40 are required even if a Company operates
in a single
       reportable segment.
       Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at
202-551-3395 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Lawrence S. Venick, Esq.