SecProbe.io

February 9, 2015

Via E -mail
M. P. Vijay Kumar
Chief Financial Officer
Sify Technologies Limited
Tidel Park, 2nd Floor
4, Rajiv Gandhi Salai
Taramani, Chennai, 600 113, India

Re: Sify Technologies Limited
 Form 20-F for the Fiscal Year Ended March 31, 2014
Filed July 21, 2014
File No. 000 -27663

Dear Mr. Kumar :

We have reviewed your filing an d have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comments , we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply 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 filing and the information you provide in
response to these comment s, we may have  additional comments.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Liquidity and capital resources, page 55

1. We note that your disclosure regarding cash flows from operating act ivities do es not
include a discussion of the reasons for the underlying changes in working capital items
that affect operating cash flows.  Please revise your disclosures in future filing to address
the material changes in the underlying drivers related to  these items and provide us with
proposed disclosure addressing our concerns .  See Section IV.B.1 of SEC Release 33 -
8350.  In this regard, we note that in your response to prior comment 4 in your letter
dated February 15, 2012 you committed to making such d isclosure but you have not done
so.

M. P. Vijay Kumar
Sify Technologies Limited
February 9, 2015
Page 2

Notes to the Consolidated Financial Statements

Note 3. Significant accounting policies

o. Revenue

Applications Integration Services, page 118

2. We note that revenue from Applications Integration Services is recognize d based on the
percentage of completion method.  Please tell us your consideration of disclosing the
methods adopted to determine the stage of completion of these transactions.  Refer to
paragraph 35 of IAS 18.

Note 13.  Trade and other receivables, page  130

3. We note your disclosure on page 131 that you maintain an allowance for doubtful
receivables based on its age and collectibility.  We also note the aging provided on page
154 which indicates that a significant portion of your trade receivables balance is past due
by 181 days or more.  Please describe your process for determining the amount of the
allowance for doubtful receivables  and tell us if you have a policy for determining when
trade rec eivables are written off.  Also, please provide us with your analysis to
substantiate that the current allowance is sufficient considering the significant balance of
trade receivable that are past due.  As part of your response, please quantify the amount
of past due trade receivable balances collected subsequent to March 31, 2014  and provide
us with an aging analysis as of September 30, 2014.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be c ertain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosu re in the filing;

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

 the company may not assert staff comments as a defense in any proceeding initia ted by
the Commission or any person under the federal securities laws of the United States.

M. P. Vijay Kumar
Sify Technologies Limited
February 9, 2015
Page 3

You may contact Eiko Yaoita Pyles, Staff Accountant , at (202) 551 -3587, or Christine
Davis, Assistant Chief Accountant,  at (202) 551 -3408, if you have questions re garding
comments on the financial statements and re lated matters.  Please contact me at (202) 551 -3406
with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief