SecProbe.io

CORRESP
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March 21, 2024

VIA EDGAR

Ms. Eileen Smiley

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: The India Fund, Inc.

Registration Statement filed on Form N-2

File Nos. 333-276892 and 811-08266

Ms. Smiley:

On behalf of The India Fund, Inc. (the “Fund”),
we are writing to respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”)
provided in a telephone conversation with Katherine Corey of abrdn Inc., Brooke Clark of Dechert LLP and me on March 7, 2024, relating
to the Fund’s registration statement on Form N-2 (the “Registration Statement”) filed on February 6, 2024.

For your convenience, the substance of those comments
has been restated below. The Fund’s response to each comment is set out immediately under the comment. Capitalized terms used in
this letter and not otherwise defined herein shall have the meanings specified in the Registration Statement.

Comments Applicable to the Prospectus

Comment 1: Please revise the Fund’s
investment objective to remove reference to investing “primarily” in the equity securities of Indian companies.

Response: The Fund notes that the
Fund’s investment objective is a fundamental policy and cannot be changed without shareholder approval. The Fund also notes that
it has a policy “to invest, under normal market conditions, at least 80% of its total assets in equity securities of Indian companies.”
The Fund has rearranged the disclosure to more prominently disclose that the Fund will invest, under normal market conditions, at least
80% of its total assets in equity securities of Indian companies.

Comment 2: Please revise the Fund’s
policy “to invest, under normal market conditions, at least 80% of its total assets in equity securities of Indian companies”
to refer to “net assets plus borrowing for investment purposes” instead of “total assets.”

Response: The Fund notes that such
policy is a fundamental policy and cannot be changed without shareholder approval. However, the Fund notes that total assets are equivalent
to net asses plus borrowing for investment purposes.

Comment 3: Please complete all bracketed
fields in the Registration Statement.

Response: The Fund has completed
all bracketed fields in the Registration Statement.

Comment 4: In the “Cautionary
notice regarding forward-looking statements” section, please include disclosure that the safe harbor provisions of Section 21E of
the Securities Exchange Act of 1934, as amended, and Section 27A of the Securities Act of 1933, as amended, do not apply to the forward-looking
statements made in the Registration Statement.

Response: The Fund has revised the
disclosure accordingly.

Comment 5: Please revise the “INCORPORATION
BY REFERENCE” section to comply with General Instruction F.3(b) of Form N-2 to state that all documents subsequently filed by the
Fund pursuant to Sections 13(a), 13(c), 14, or 15(d) of the Exchange Act, prior to the termination of the offering shall be deemed to
be incorporated by reference into the Registration Statement.

Response: The Fund has revised the
disclosure accordingly.

Comment 6: Please include hyperlinks
to the documents incorporated by reference in the Registration Statement.

Response: The Fund has revised the
disclosure accordingly.

Comment 7: If the Registration Statement
becomes effective prior to the Fund filing its 2023 Annual Report, please update the Registration Statement to reference the latest Annual
Report pursuant to General Instruction F.3(a) of Form N-2.

Response: The Fund confirms that
its 2023 Annual Report was filed with the SEC on March 11, 2024.

Comment 8: With respect to the fee
table and expense example included in the “SUMMARY OF FUND EXPENSES” section, if the fee table includes expenses associated
with a preferred stock offering, please update the fee table and expense example accordingly.

Response: The Fund has revised the
disclosure accordingly.

Comment 9: With respect to the fee
table included in the “SUMMARY OF FUND EXPENSES” section, please include a footnote explaining that “Other expenses”
are based on estimated amounts for the current fiscal year.

Response: The Fund has revised the
disclosure accordingly.

Comment 10: With respect to the
 “Investment objective, strategies and policies” discussion, please supplementally explain whether convertible bonds count
towards the Fund’s policy to invest, under normal market conditions, at least 80% of the Fund’s total assets in equity securities
of Indian Companies.

Response: The Fund confirms that
convertible bonds count towards the Fund’s policy to invest, under normal market conditions, at least 80% of the Fund’s total
assets in equity securities of Indian Companies.

Comment 11: With respect to the
 “Investment objective, strategies and policies” discussion, please clarify whether the definition of “Indian companies”
also includes debt securities issued by Indian companies.

Response: The Fund respectfully
acknowledges the Staff’s comment and believes that the current disclosure sufficiently explains that the Fund will invest at least
80% of its total assets in equity securities of “Indian companies” and that the definition of “Indian companies”
that appears immediately after the Fund’s 80% policy, relates directly to the 80% policy. The Fund notes that investments in debt
securities of Indian companies do not count towards the Fund’s 80% policy, as disclosed in the Registration Statement.

Comment 12: Please clarify whether
Fund assets that are invested in debt securities other than temporary investments count towards the Fund’s policy to invest, under
normal market conditions, at least 80% of the Fund’s total assets in equity securities of Indian Companies.

Response: Please see the Fund’s
response to Comment 11. The Fund notes that investments in debt securities other than temporary investments do not count towards the Fund’s
80% policy, as disclosed in the Registration Statement.

Comment 13: Please supplementally
explain what percentage of the Fund’s assets may be invested in investment funds relying on Sections 3(c)(1) or 3(c)(7) of the Investment
Company Act of 1940, as amended (the “1940 Act”).

Response: The Fund notes that none
of its assets are currently invested in investment funds relying on Sections 3(c)(1) or (3)(c)(7) of the 1940 Act and that it does not
currently intend to invest its assets in investment funds relying on Sections 3(c)(1) or 3(c)(7) of the 1940 Act.

Comment 14: Please disclose how
the Investment Manager defines each of the following factors: “(1) durability of the business model, (2) the attractiveness of the
industry, (3) the strength of financials, (4) the capability of management, and (5) the most material environmental, social and governance
(“ESG”) factors impacting a company.”

Response: The Fund respectfully
acknowledges the Staff’s comment and believes that the current disclosure is written in plain English and is sufficiently clear.
The Fund notes that, as disclosed in the Registration Statement, the Investment Manager’s quality assessment of companies covers
the five enumerated factors. That is, these factors are considered wholistically by the Investment Manager in its evaluation of a company.
How the Investment Manager determines the “durability of a business model,” the “attractiveness of an industry”
and so on, is part of the Investment Manager’s proprietary investment process. The Fund further notes that ESG factors considered
by the Investment Manager are disclosed immediately following the description of the 5-factor quality assessment.

Comment 15: Under the “Convertible
Securities” section, please complete the following statement: “the potential for capital appreciation in the market price
of the underlying common stock.”

Response: The Fund has revised the
disclosure accordingly.

Comment 16: Under the “Loans
of Portfolio Securities” section, with respect to the disclosure that the Fund may experience delays in recovering the securities
that it has lent, please address that the Fund may not recover the securities that it has lent in time to vote as a shareholder with respect
to such securities.

Response: The Fund has revised the
disclosure accordingly.

Comment 17: If the cost to invest
in other investment funds exceeds one basis point, please include a corresponding line item in the fee table.

Response: The Fund confirms that
if the cost to invest in other investment funds exceeds one basis point, a corresponding line item will be included in the fee table.

Comment 18: With respect to “The
Investment Manager” section:

 a. Please supplementally explain the nature of the arrangement covered by the
MOU. Such explanation should cover, at a minimum, the following:

 (i) Identify the affiliate(s) of the Investment Manager who may render portfolio
management, research or trading services to the Fund;

 (ii) Identify the country of domicile of the affiliate(s);

 (iii) Explain the control relationship between the Investment Manager and the
affiliate(s); and

 (iv) State whether the affiliate(s) is a registered entity with the SEC.

Response:

    Entity
    Country of Domicile
    Relationship to the

 Investment Manager*
    Registered Entity with

the SEC

    abrdn Inc.
    USA
    Sister company
    Yes

    abrdn Investments Limited (formerly, Aberdeen Asset Managers Limited)
    England
    Sister company
    Yes

    abrdn Alternative Funds Limited (formerly, Aberdeen Standard Alternative Funds Limited)
    Scotland
    Sister company
    Yes

    abrdn ETFs Advisors LLC
    USA
    Sister company
    Yes

    Aberdeen Asset Management (Thailand) Limited
    Thailand
    Sister company
    No

    abrdn Brasil Investimentos Ltda
    Brazil
    Sister company
    No

    abrdn Hong Kong Limited
    Hong Kong
    Sister company
    No

    abrdn Malaysia SDN BHD
    Malaysia
    Sister company
    No

    abrdn Islamic Malaysia SDN BHD
    Malaysia
    Sister company
    No

    abrdn Investment Management Limited
    Scotland
    Sister company
    No

    Ignis Investment Services Limited
    Scotland
    Sister company
    No

*All companies are
directly or indirectly wholly owned by abrdn plc.

 b. Please supplementally explain why the MOU is not an advisory contract within
the meaning of 1940 Act. Please address:

 (i) Specific services the affiliate(s) and its employees will provide;

 (ii) The extent to which the Investment Manager will depend on affiliate personnel;

 (iii) Whether affiliate personnel who provide investment advice with respect to
the Fund will be supervised persons of the Investment Manager under Section 202(a)(25) of the Investment Advisers Act of 1940, as
amended;

 (iv) Whether the affiliate(s) is considered a fiduciary with respect to the Fund;
and

 (v) Confirm that the records created by the affiliate(s) in providing services
to the Fund required to be maintained pursuant to the 1940 Act are records of the Fund and the location where such records will be maintained.

Response: The Investment
Manager is a party to the MOU pursuant to which Participating Registered Advisers, Participating Affiliates (each as defined in the MOU)
and their respective employees (collectively, “Supervised Persons”) may perform certain portfolio management, research or
trading services, including (i) serving as a discretionary asset manager, (ii) participating in telephone calls or in-person meetings
for the purpose of discussing industry trends, market developments, economic forecasts, and other information related to the management
of investment portfolios, (iii) meeting from time to time with governing boards to discuss management and performance of certain accounts,
(iv) producing written research reports, (v) placing orders for purchase and sale of portfolio securities or other assets, and (vi) performing
compliance, administrative and clerical functions. Supervised Persons will provide resources and services to the Investment Manager only
and will not be contracting directly with the Fund to provide any services or receive any advisory fees or compensation of any kind from
the Fund. Supervised Persons will receive their compensation from their respective employing Participating Affiliate or Participating
Registered Adviser. Any Supervised Person who provides investment advice with respect to the Fund will be a supervised person of the Investment
Manager under Section 202(a)(25) of the Investment Advisers Act of 1940, as amended, which is a fiduciary to the Fund. As such, the
MOU does not amount to an advisory contract under the 1940 Act. Thus, the Supervised Persons are not considered fiduciaries with respect
to the Fund.

The Fund confirms that Participating
Affiliates and Participating Registered Advisers will make and keep books and records of the Fund as required by and in such location
as required by the 1940 Act.

 c. Please supplementally explain if the Investment Manager is relying on any no-action relief with respect
to the arrangement under the MOU.

Response: The Fund confirms
that the arrangement under the MOU is consistent with the “Unibanco letters” (See, e.g., ABA Subcommittee on Private
Investment Entities, SEC Staff No-Action Letter (Dec. 8, 2005; Royal Bank of Canada, SEC Staff No-Action Letter (June 3, 1998); ABN AMRO
Bank, N.V., SEC Staff No-Action Letter (July 7, 1997); Murray Johnstone Holdings Limited, SEC Staff No-Action Letter (Oct. 7, 1994); Kleinwort
Benson Investment Management Limited, SEC Staff No-Action Letter (Dec. 15, 1993); Mercury Asset Management plc, SEC Staff No-Action Letter
(Apr. 16, 1993); and Uniao de Bancos de Brasileiros S.A., SEC Staff No-Action Letter (July 28, 1992)). abrdn
previously reported information to the SEC’s Chief Counsel’s Office regarding abrdn affiliates participating in personnel
sharing arrangements and reliance on the “Unibanco Letters” as outlined in the March 2017 IM Information Update for Advisers
Relying on the Unibanco No-Action Letters.

Comment 19: In the “INVESTMENT
OBJECTIVE AND PRINCIPAL INVESTMENT STRATEGY” section, please make conforming changes with respect to the revisions made in response
to the Comments above, as applicable.

Response: The Fund has revised the
disclosure accordingly.

Comment 20: The Staff notes that
the discussion in the “INVESTMENT OBJECTIVE AND PRINCIPAL INVESTMENT STRATEGY” section is similar to discussion included in
prior sections of the Registration Statement. Please consider revising the earlier discussion regarding the Fund’s investment objective
and principal investment strategy to be more concise.

Response: The Fund has revised the
disclosure accordingly.

Comment 21: The Staff notes that
the following disclosure is included in the “RISK FACTORS” section: “Each of the risk factors contained thereunder is
a principal risk of the Fund.” Please clarify the disclosure with respect to the location of the discussion of non-principal risks
of the Fund.

Response: The Fund has revised the
disclosure accordingly.

Comment 22: Please supplementally
confirm that the Fund has not opted into the Maryland Control Share Acquisition Act.

Response: The Fund so confirms.

Comment 23: Under the “DESCRIPTION
OF SUBSCRIPTION RIGHTS” section, please disclose whether the Fund has issued any subscription rights to date.

Response: The Fund has revised the
disclosure accordingly.

Comment 24: Please revise the “Reverse
Repurchase Agreements” section to align with the requirements of Rule 18f-4 under the 1940 Act.

Response: The Fund has revised the
disclosure accordingly.

Comments Applicable to the Statement of Additional
Information

Comment 25: Under the “Investment
Restrictions” section, please revise the Fund’s policy “to invest, under normal market conditions, at least 80% of its
total assets in equity securities of Indian companies” to refer to “net assets plus borrowing for investme