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CORRESP

 SIFY TECHNOLOGIES LIMITED

Tidel Park, Second Floor

 No. 4, Rajiv Gandhi Salai, Taramani

 Chennai 600 113

India

 VIA EDGAR

 February 15, 2012

Division of Corporation Finance

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington D.C. 20549

 Attention: Mr. Patrick Gilmore

 Accounting Branch Chief

Re:
Sify Technologies Limited—Form 20-F for the Fiscal Year Ended

March 31, 2011, filed on October 13, 2011

Form 6-K furnished on October 26, 2011

Form 6-K furnished on January 30, 2012

File No. 000-27663

 Dear Mr. Patrick,

 This letter is submitted on behalf of
Sify Technologies Limited (the “Company” or “we”) in response to the comments of the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Staff”), as set forth in your letter (the
“Comment Letter”) to M P Vijay Kumar dated February 3, 2012 with the respect to the Company’s Annual Report on Form 20-F for the fiscal year ended March 31, 2011 (the “Annual Report”), the Form 6-K furnished on
October 26, 2011 and Form 6-K furnished on January 30, 2012. For reference purposes, the text of your letter has been reproduced herein with responses below each numbered comment.

 General:

 Comment 1: We note that you have a minority interest in
MF Global Sify Securities India Private Limited and that MF Global Sify Securities Private Limited owns the majority interest. Please explain to us how you considered whether to furnish a Form 6-K after MF Global Holdings Ltd., the ultimate parent
of MF Global Sify Securities Private Limited, filed for bankruptcy on October 31, 2011. See General Instruction B to Form 6-K.

Response 1:

 MF Global
Sify Securities India Private Limited (“MFG Sify”) is not a subsidiary of the Company. Sify owns approximately a 30% minority interest in MFG Sify. As noted in the Annual Report, our non-controlling minority interest is accounted for under
IFRS using the equity method of accounting. The Company reviewed the bankruptcy filing of the parent of MFG Sify and after consultation with executives of MFG Sify and an evaluation by our management, we determined that the bankruptcy filing did
not, at such time, materially affect MFG Sify or the Company’s interests in MFG Sify. The Company will file a Form 6-K in the event of any material development impacting Sify’s interest in MFG Sify, or upon the occurrence of any event that
would require disclosure on Form 6-K.

 Comment 2: As a related matter, please tell us how the bankruptcy of MF Global
Holdings Ltd. affected the valuation of your investment in MF Global Sify Securities India Private Limited as of your most recent balance sheet date. Please provide us with your analysis pursuant to paragraphs 31 and 33 of IAS 28 in determining
whether an impairment of your investment in this equity accounted investee has occurred during your most recent fiscal quarter.

 Response 2:

 As disclosed in our Annual Report, our interest in MFG Sify is accounted for under IFRS using the equity method of accounting. Under this method, we generally are obligated to report as “share of
profit of equity accounted investee” a pro rata portion of the net income after tax of MFG Sify in our statement of operations even though we do not control MFG Sify, subject to limitations in the case of losses that exceed our cost of
investment.

 MFG Sify and its subsidiaries have continued to be solvent and continued to carry on business in the ordinary
course, and have not been impacted by MFG US bankruptcy. The impairment indicator was evaluated as of December 31, 2011 and the recoverable amount was assessed as higher than carrying amount based on bid prices of a prospective buyer for the
purchase of the shares of MFG Sify held by its parent corporation, MFG Holdings Limited. We will conduct an impairment evaluation of the valuation of our interest in MFG Sify again as of the end of our fiscal year on March 31, 2012, and such
analysis will be disclosed in our annual report on Form 20-F for the fiscal year ending March 31, 2012.

 Form 20-F for the Fiscal Year
Ended March 31, 2011

 Item 5. Operating and Financial Review and Prospects

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

Liquidity and capital resources, page 52

 Comment 3: Please tell us how you considered discussing the Indian regulations that restrict your ability to raise funds by issuing additional ADSs in the United States or listing in India. See
Item 5.B.1 of Form 20-F.

 Response 3:

 The Company respectfully believes that it addressed the relevant Indian regulations regarding its current inability to raise additional funds in the United States or effect a listing in India. As
mentioned in the risk factors and the Notes to the Financial Statements on page 159 of the Annual Report, under the restrictions imposed by the Ministry of Finance of the Government of India (the “MoF”), the Company is not permitted to
raise any capital by issuing additional American Depositary Shares in the United States, unless and until the Company is first listed on the Indian stock exchanges.

 The Company is not able to list its shares on the Indian stock exchanges due to its inability to comply with the listing requirements of Securities Exchange Board of India, particularly per Clause 26
(1) (b) of the Issue of Capital and Disclosure Requirement Regulations, 2009, which requires that prior to a listing on the Indian stock exchange, the issuer must have a track record of “Distributable Profits” in terms of
Section 205 of the Indian Companies Act, 1956, for at least three out of immediately preceding five years, provided that extraordinary items shall not be considered for calculating such distributable profits. As the Company has not been
profitable during any of the three previous years, it may not list its shares in India.

 In view of the above legal
restrictions, the Company is not currently permitted to either issue and sell additional American Depositary Shares in the United States or list shares in India.

 Comment 4: We note that your disclosures regarding cash flows from operating activities do 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 filings to address the material changes in the underlying drivers related to these items. See Section IV.B.1 of SEC Release 33-8350.

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 Response 4:

 We note the Staff’s comment and will provide further disclosure regarding material changes in our future filings.

 Item 6. Directors, Senior Management and Employees:

 Board Compensation, page 65:

 Comment 5: Notwithstanding your representations in your March 16, 2009 response to comment 8 of our letter
dated February 9, 2009, you do not appear to have disclosed the date of expiration of the current term of office of each of your directors, and members of your administrative, supervisory or management bodies. See Item 6.C.1 of Form 20-F.
Please advise.

 Response 5:

 As stated in the Annual Report, the Company has service contracts with Mr. Raju Vegesna, CEO & Managing Director and Mr. Ananda Raju Vegesna, Executive Director.

The tenure of office of Mr. Raju Vegesna and Mr. Ananda Raju Vegesna is five years from the date of election, effective
July 18, 2009 and June 22, 2010, respectively. As per the Company’s Articles of Association, these two Directors are not required to retire by rotation and shall serve until they resign.

As described in the Annual Report, the Company does not have a service contract with the other directors. However, under the Indian
Companies Act, 1956, two-thirds of the remaining Directors are required to retire by rotation. Of this, one-third shall retire at every annual general meeting (“AGM”). At every AGM, the Directors who have served for the longest period
since their last appointment shall retire by rotation. The retiring Directors are eligible for re-election by the stockholders and may be nominated for election by the Company. Hence, the Directors who are retiring by rotation are determined only
close to AGM and cannot be determined in advance.

 The Company will provide further details regarding the election and terms
of each director in its future filings. The Company does not have administrative, supervisory or management bodies. The members of each standing committee of the Board of Directors are described in the Annual Report.

Stock Ownership, page 66

Comment 6: Footnote 1 to the beneficial ownership table states that “All 125,000,000 shares have been allotted to
Mr. Vegesna and his affiliated entities, as all shares are issued and outstanding.” The footnote appears to be referencing the 125 million shares purchased in the October 2010 unregistered offering. Please clarify this in future
filings by expanding the footnote or including a cross-reference to a more detailed explanation elsewhere in your annual report.

 Response
6:

 We note the Staff’s comment and will provide a detailed explanatory footnote and/or a cross-reference in our
future filings regarding the ownership of Mr. Vegesna’s shares.

 Item 7. Major Shareholders and Related Party Transactions

 Principal Shareholders, page 67

 Comment 7: In the third sentence of this section, you state that beneficial ownership includes “voting and investment power with respect to equity shares.” Please note that beneficial
ownership also includes the power to receive the economic benefit of ownership of securities. See General Instruction F to Form

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20-F. Please tell us whether you have provided the disclosure required by Item 7 of Form 20-F for all shareholders that are the beneficial owners of 5% or more of each class of your voting
securities. In addition, please confirm that you will include disclosure consistent with Form 20-F’s definition of beneficial owners in future filings.

 Response 7:

 The Company believes it has provided the disclosure required
under Item 7 for all shareholders who are the beneficial owners of more than 5% of each class of our voting securities, and will provide such disclosure consistent with Form 20-F’s definition of beneficial ownership in future filings.
Mr. Raju Vegesna is the sole shareholder that is the beneficial holder of greater than 5% of the Company’s outstanding shares.

Issuance of Equity Shares in private placement to the promoter group, page 69

Comment 8: It appears that your issuance of equity shares to your promoter group was done at a discount to the trading price of
your ADSs at the time of the transaction. Please explain how you determined that additional disclosure was not necessary. See Item 7.B.1 of Form 20-F.

 Response 8:

 As mentioned in Note 42 in the Notes to the financial
statements included in the Annual Report, the Company issued and allotted 125,000,000 Equity Shares to M/s Raju Vegesna Infotech and Industries Private Limited, pursuant to the terms of the Subscription Agreement dated October 22, 2010, by and
between the Company and Mr. Ananda Raju Vegesna, acting as a representative for the promoter group companies. Mr. Raju Vegesna, the Company’s Chief Executive Officer, and entities affiliated with Mr. Vegesna, comprised the
promoter group (the “Promoter Group”). A copy of the Subscription Agreement was filed with SEC on a Form 6-K filed on November 15, 2010.

 The transaction with the Promoter Group was approved by the Board of Directors, including all independent members of the Board of Directors, in August 2010, and by the Company’s shareholders at
the Company’s Annual General Meeting in September 2010, in accordance with Indian law. The proxy materials distributed to the Company’s shareholders prior to the annual general meeting at which the transaction was voted upon disclosed
the purchase price of the shares sold to the Promoter Group. Moreover, the Company issued a press release on August 28, 2010 describing the terms of the proposed transaction with the Promoter Group, including the discounted share price, and
filed a Form 6-K with such press release on August 31, 2010.

 In view of the above, the Company determined that no
additional disclosure was required in the Annual Report, as the material information regarding the terms of the transaction was previously disclosed.

 Item 10. Additional Information

 Exchange Controls

Issue of shares by Indian companies under ADR/GDR, page 81

 Comment 9: Although you have included a general discussion of the laws that appear to currently restrict your ability to currently issue any additional ADRs, please tell us how you considered
disclosing that you currently face such restrictions. See Item 10.D of Form 20-F.

 Response 9:

As stated in our response to Comment 3 above, the Company respectfully submits that it fully disclosed the restrictions imposed by the
Indian government regarding the Company’s ability to issue additional American Depositary Shares in the United States, and that any future issuance are prohibited until such time as the Company lists its shares on the Indian stock exchange.

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 In addition to the risk factor and the discussion in the Company’s notes to the
financial statements in the Annual Report, the Company will add further disclosure regarding such restrictions in future filings in response to the Staff’s comment.

 Item 18. Financial Statements

 Note 3. Significant accounting policies

 n. Revenue

 (i) Corporate network/data services, page 118

 Comment 10: We note
your disclosure that trading transactions relating to standard hardware and software involve the arrangement of purchases from suppliers and sales to customers and that revenue is reported on a gross or net basis depending on a fact-specific
evaluation of such transactions. Please tell us more about the nature of these transactions. As part of your response, describe the details of an arrangement that results in revenue being reported gross and another when revenue is reported net,
including your analysis pursuant to the example in paragraph 21 of IAS 18 IE in determining whether you are a principal or an agent in the respective transactions.

 Response 10:

 As part of the Company’s expansion of its enterprise
solutions business, we identified the business of System Integration as one of the revenue streams. This business primarily involves trading of networking hardware and software.

The Company evaluated the above transactions on a fact specific basis for gross or net reporting based on the following principles as set
out in paragraph 21 of IAS 18 IE. According to paragraph 21 of IAS 18 IE, the following principles indicate that an entity would be acting as a principal.

•

 the entity has primary responsibility for providing the goods or services to the customer or for fulfilling the order.

•

 the entity has inventory risk before or after the customer order, during shipping on or return.

•

 the entity has latitude in establishing prices, either directly or indirectly, for example by providing additional goods or services.

•

 the entity bears the customer’s credit risk for the amount receivable from the customer.

During the year ended March 31, 2011, on evaluation of these transactions from a gross – net reporting perspective, the Group
has evaluated the significant risks and rewards associated with the purchase and sale of such goods. Specifically, in cases where there were no credit risk assumed by the Company, in as much as the payment to the vendor was made only after
collecting from the customer and the inventory risk is not owned by the Company, the Company has recorded such transaction on a net basis.

 Alternatively, the revenue is recorded on a gross basis, when the Company acts as a principal. Thus in typical transactions, where the credit risk is owned by the Company, inventory risk owned by the
Company and all significant risks and rewards are owned by the Company, the transactio