SecProbe.io

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March 18, 2016

Jim B. Rosenberg

Senior Assistant Chief Accountant

Office of Healthcare and Insurance

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Re: Elite Pharmaceuticals, Inc.

Form 10-K for the Fiscal Year
Ended March 31, 2015 Filed June 15, 2015

Form 10-Q/A for the Quarterly Period Ended September
30, 2015 Filed December 30, 2015 File No. 001-15697

Dear Mr. Rosenberg:

Elite Pharmaceuticals, Inc. (the "Company")
hereby responds to the oral comments received from the SEC’s Staff on March 4, 2016 concerning the above referenced Company
filings.

COMMENT
NO. 1.

 1. Refer to our prior comment 1. Please revise your proposed policy disclosure
to remove reference to fair value in determining your revenue recognition. This requirement was removed by ASU 2009-13. Refer to
ASC 605-25-25-5.

RESPONSE.

The
Company, in future filings, will include the following disclosure regarding revenue recognition:

The
Company enters into licensing, manufacturing and development agreements which may include multiple revenue generating activities,
including, without limitation, milestones, license fees, product sales and services. These multiple elements are assessed in accordance
ASC 605-25 Revenue Recognition for Multiple-Element Arrangements in order to determine whether particular components of the arrangement
represent separate units of accounting.

165 Ludlow Avenue •
Northvale, NJ 07647 • Ph: (201)750-2646 • Fax: (201)750-2755 www.elitepharma.com

An
arrangement component is considered to be a separate unit of accounting if the deliverable relating to the component has value
to the customer on a standalone basis, and if the arrangement includes a general right of return relative to the delivered item,
delivery or performance of the undelivered item is considered probable and substantially in control of the Company.

The
Company recognizes payments received pursuant to a multiple revenue agreement as revenue, only if the related delivered item(s)
have stand-alone value, with the arrangement being accordingly accounted for as a separate unit of accounting. If such delivered
item(s) are considered to either not have stand-alone value, the arrangement is accounted for as a single unit of accounting, and
the payments received are recognized as revenue over the estimated period of when performance obligations relating to the item(s)
will be performed.

Whenever
the Company determines that an arrangement should be accounted for as a single unit of accounting, it determines the period over
which the performance obligations will be performed and revenue will be recognized. If it cannot reasonably estimate the timing
and the level of effort to complete its performance obligations under a multiple-element arrangement, revenues are then recognized
on a straight-line basis over the period encompassing the expected completion of such obligations, with such period being reassessed
at each subsequent reporting period.

Arrangement
consideration is allocated at the inception of the arrangement to all deliverables on the basis of their relative selling price
(the relative selling price method). When applying the relative selling price method, the selling price of each deliverable is
determined using vendor-specific objective evidence of selling price, if such exists; otherwise, third-part evidence of selling
price. If neither vendor-specific objective evidence nor third-party evidence of selling price exists for a deliverable, the Company
uses its best estimate of the selling price for that deliverable when applying the relative selling price method. In deciding whether
we can determine vendor-specific objective evidence or third-party evidence of selling price, the Company does not ignore information
that is reasonably available without undue cost and effort.

When
determining the selling price for significant deliverables under a multiple-element revenue arrangement, the Company considers
any or all of the following, depending on information available or information that could be reasonably available without undue
cost and effort: vendor-specific objective evidence, third party evidence or best estimate of selling price. More specifically,
factors considered can include, without limitation and as appropriate, size of market for specific a product, number of suppliers
and other competitive market factors, forecast market shares and gross profits, barriers/time frames to market entry/launch, intellectual
property rights and protections, exclusive or non-exclusive arrangements, costs of similar/identical deliverables from third parties,
contractual terms, including, without limitation, length of contract, renewal rights, commercial terms, profit allocations, and
other commercial, financial, tangible and intangible factors that may be relevant in the valuation of a specific deliverable.

165 Ludlow Avenue •
Northvale, NJ 07647 • Ph: (201)750-2646 • Fax: (201)750-2755 www.elitepharma.com

    -2-

COMMENT
NO. 2.

 2. Refer to your response to our prior comment 3. Your proposed disclosures appear
limited to revenues for your NDA and ANDA reportable segments. Please provide us proposed disclosures to be included in future
periodic reports that include a measure of profit and loss by segment, in addition to other disclosures required by ASC-280-10-50-22
through 36.

RESPONSE.

The
following are the proposed disclosures:

Note
XX: Segment Results

FASB
ASC 280-10-50, “Disclosure about Segments of an Enterprise and Related Information” requires use of the “management
approach” model for segment reporting. The management approach is based on the way a company’s management organizes
segments within the company for making operating decisions and assessing performance. Reportable segments are based on products
and services, geography, legal structure, management structure, or any other manner in which management disaggregates a company.

The
Company disaggregates its product revenues into the type of marketing authorization relating to each product, specifically the
following two reportable segments:

1.ANDA’s
for generic products; or

2.NDA’s
for branded products.

165 Ludlow Avenue •
Northvale, NJ 07647 • Ph: (201)750-2646 • Fax: (201)750-2755 www.elitepharma.com

    -3-

The
following represents selected information for the Company’s reportable segments for the (enter periods
here):

    Columns for periods (as appropriate)

    Revenues from external customers

    ANDA

    NDA

    Adjusted income from continuing operations before income tax

    ANDA

    NDA

The
table below provides reconciliations of the Company’s segment adjusted income from continuing operations before income tax,
for the (enter periods here):

    Columns for periods (as appropriate)

    Total segment adjusted income from continuing operations before income tax

    Corporate unallocated costs

    Interest revenue

    Interest expense

    Depreciation and amortization expense

    Unusual items as per ASC 225-20-45-16

    Income tax expense or benefit

    Significant noncash items other than depreciation and amortization expense

    Other income

    Other expense

    Total income(loss) from continuing operations before income tax

Asset
information is not reviewed or included within the Company’s internal management reporting. Accordingly, the Company has
not disclosed asset information for each reportable segment.

165 Ludlow Avenue •
Northvale, NJ 07647 • Ph: (201)750-2646 • Fax: (201)750-2755 www.elitepharma.com

    -4-

COMMENT
NO. 3.

 3. Please represent to us that you will furnish your future earnings releases
under item 2.02 of Form 8-K or tell us why you do not provide such filings.

RESPONSE.

Pursuant
to Item 2.02(a) of Form 8-K, a Form 8-K is required to be filed “[i]f a registrant, or any person acting on its behalf, makes
any public announcement or release (including any update of an earlier announcement or release) disclosing material non-public
information regarding the registrant's results of operations or financial condition for a completed quarterly or annual fiscal
period, …” (Emphasis added)

The
Company’s practice is to issue earnings releases only after the relevant annual report on Form 10-K or Quarterly Report on
Form 10-Q is filed. The Company does not believe that there is any “material non-public information” in its earnings
releases. Accordingly, in such instances, the Company does not believe that it is required to file a Current Report on Form 8-K
under Item 2.02. Should the Company believe that in future earnings releases there will be any material non-public information
requiring disclosure under item 2.02, it plans on filing the requisite Form 8-K.

As required, the Company acknowledges that:

 · the Company is responsible for the adequacy and accuracy of the disclosure in its filings with
the Commission;

 · staff comments or changes to disclosure in response to staff comments do not foreclose the Commission
from taking any action with respect to the filings; and

 · the Company may not assert the staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

If you have any questions or comments with
regard to the filing, please contact me at the above address.

    Very truly yours,

    /s/ Carter Ward

    Carter Ward, CFO

165 Ludlow Avenue •
Northvale, NJ 07647 • Ph: (201)750-2646 • Fax: (201)750-2755 www.elitepharma.com

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