SecProbe.io

January 21, 2020
William Coote
Vice President, Treasurer
TARO PHARMACEUTICAL INDUSTRIES LTD
3 Skyline Drive
Hawthorne, New York 10532
Re:TARO PHARMACEUTICAL INDUSTRIES LTD
Form 20-F for Fiscal Year Ended March 31, 2019
Filed June 20, 2019
File No. 001-35463
Dear Mr. Coote:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comments, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for Fiscal Year Ended March 31, 2019
Note 2: - Significant Accounting Policies
b. Financial statements in U.S. dollars, page F-12
1.We note that effective April 1, 2019, you changed the functional currency for Taro
Canada from the Canadian dollar to the U.S. dollar.  Please (i) identify the significant
changes in economic facts and circumstances that indicated this functional currency had
changed in accordance with ASC 830-10-45-7, and (ii) identify the economic facts and
circumstances that remained constant since your initial determination of this functional
currency.  Your response should analyze all relevant factors consistent with the guidance
in ASC 830-10-55-5.  Finally, consider the need to disclose the nature and timing of this
change, the actual and reasonably likely effects of this change, and economic facts and
circumstances that led management to conclude that this change was appropriate. The
material effects of those underlying economic facts and circumstances on your business
should also be discussed in MD&A.

 FirstName LastNameWilliam Coote
 Comapany NameTARO PHARMACEUTICAL INDUSTRIES LTD
 January 21, 2020 Page 2
 FirstName LastName
William Coote
TARO PHARMACEUTICAL INDUSTRIES LTD
January 21, 2020
Page 2
            In closing, 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.
            You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or Jeanne Baker,
Staff Accountant, at (202) 551-3691 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences