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SIFY TECHNOLOGIES LIMITED

Tidel Park, Second Floor

No. 4, Rajiv Gandhi Salai, Taramani

Chennai 600 113

India

January 8, 2025

Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington D.C. 20549

 Attention: Claire
                                            DeLabar

  Robert Littlepage

    Re:
    Sify Technologies Ltd.

Form 20-F for the Fiscal Year Ended March 31, 2024

Response dated December 10, 2024

File No. 000-27663

Dear Ms. DeLabar and Mr. Littlepage,

This letter is submitted on behalf of Sify Technologies
Limited (the “Company”, “Sify” or “we”) in furtherance of the call with the staff members of the
Securities and Exchange Commission (the “Staff”) on January 6, 2025, and in continuation to our response letter dated December
10, 2024. We respectfully submit the additional information below requested on the January 6, 2025 call with the Staff with respect to
certain selected amendments and disclosures that we propose to make in the Amendment No. 1 on Form 20-F/A.

 1) Disclosure in Explanatory note for filing Form 20-F/A:

This Amendment No. 1 on Form 20-F/A (the “Amendment
No. 1”) amends the Annual Report on Form 20-F of Sify Technologies Limited (the “Company” or “Sify”) for
the year ended March 31, 2024 (the “Original Form 20-F”), filed on May 7, 2024, with the Securities and Exchange Commission
(the “SEC”) in response to certain comments raised by the Staff of the SEC.

In this Amendment No. 1, the Company is refiling
its financial statements presented in the Original Form 20-F in order to restate the presentation of its Compulsorily Convertible Debentures
(“CCDs”) in the Consolidated Statement of Financial Position and its resulting impact on the Consolidated Statements of Comprehensive
Income, Consolidated Statements of Changes in Equity and Consolidated Statements of Cash Flows for each of the two years ended March
31, 2024 and March 31, 2023. As a result of the change in presentation, Series 1 and Series 2 CCDs amounting to Rs. 4,000 million are
treated as liabilities instead of equity as previously presented in the financial statements in the Original Form 20-F. The present value
of interest payments of the Series 4 CCDs of Rs. 2,076 million are also presented as a liability instead of equity as in the Original
Form 20-F, but the remaining value of Rs. 2,724 million continues to be presented as equity. For the Series 5 CCDs, the present value
of interest payments of Rs. 518 million is similarly now presented as a liability, while the remaining value of Rs. 682 million is assigned
to the other component. The residual component of the Series 5 CCDs will be treated as a financial liability until the fixed conversion
ratio of the Company’s equity shares is determined. For additional information see Note 19 in the notes to our financial statements.

Additionally, the Company
is expanding disclosure regarding conversion terms of CCDs and other items in the Financial Statements including: (i) changes describing
the accounting treatment of the CCDs under Notes 16A, 19 and 28 to our financial statements; (ii) providing the depreciation policy for
“improvements forming part of the building-5 years” under Item 18 , (iii) inclusion of a clarifying parenthetical for Other
Bank deposits under Note 8 to our financial statements, denoting that such have a maturity period longer than 3 months; (iv) additional
disclosure for “Financial assets included in Other Assets” under Note 10 to our financial statements; (v) additional disclosure
relating to the accounting of 64.6 million rupees under the Service tax contingency under Note 31 of our financial statements; (vi) additional
disclosure related to contract breaches and conditions for conversion pursuant to the put option agreement under contingency under Note
31 to our financial statements; (vii) disclosure relating to conversion terms of CCDs under Note 19 to our financial statements; and
(viii) minor typographical and clerical changes. We have also made corresponding changes to reflect the changes in our financial statement
to Item 3 and Item 5 of this Amendment No. 1.

Due to the amendment in
presentation of CCDs in the financial statements filed with the Original Form 20-F, the Company has re-evaluated the effectiveness of
the Company’s internal control over financial reporting as of March 31, 2024 and identified material weakness in the Company’s
internal control over financial reporting that existed, relating to the classification of the CCDs. As a result, Item 15 of Original
Form 20-F has been similarly amended in this Amendment No. 1 and we have added a risk factor with regards to the found material weakness
under Item 3 of this Amendment No.1 See Item 3. — Risk Factors. — “We have identified material weakness in our internal
control over financial reporting. If we are unable to maintain an effective system of internal control over financial reporting, we may
not be able to accurately report our financial results or prevent or detect fraud. As a result, current and potential investors could
lose confidence in our financial reporting, which could harm our business and have an adverse effect on our ADS price.

This Amendment No. 1 includes
currently dated certifications from the Chief Executive Officer and Chief Financial Officer, as required by Sections 302 and 906 of the
Sarbanes-Oxley Act of 2002 (included in this Amendment No. 1 as Exhibits 12.1, 12.2, 13.1 and 13.2). Except as described above, this
Amendment No. 1 does not amend, update or change any other items or disclosures in the Original Form 20-F and does not purport to reflect
any information or events subsequent to the filing thereof. As such, this Amendment reflects all information as of the date the Original
Form 20-F was filed, and the Company has not undertaken herein to amend, supplement or update any information contained in the Original
Form 20-F to give effect to any subsequent events. Accordingly, this Amendment should be read in conjunction with the Original Form 20-F
and any subsequent filings by the Company with the SEC.

 2) Insertion in Item 3-Risk factors

We have identified material weakness in our
internal control over financial reporting. If we are unable to maintain an effective system of internal control over financial reporting,
we may not be able to accurately report our financial results or prevent or detect fraud. As a result, current and potential investors
could lose confidence in our financial reporting, which could harm our business and have an adverse effect on our ADS price.

For the year ended March 31, 2024, we identified
material weakness in our internal control over financial reporting with respect to the design and implementation of effective controls
to ensure the appropriate application of IFRS for reporting and presentation of complex financial instruments. A material weakness is
a deficiency, or combination of deficiencies, in internal control over financial reporting such that there is a reasonable possibility
that a material misstatement of a company’s annual or interim financial statements will not be detected or prevented on a timely
basis.

Specifically, the material
weakness that were identified, individually or in the aggregate, related to the design and implementation of effective controls to ensure
the appropriate application of IFRS for reporting and presentation of complex financial instruments, as further explained in the Explanatory
Note in this Amendment No. 1. We have taken steps to develop a remediation plan designed to address the material weakness described above
and expect to take additional steps to fully remediate our material weakness. We intend to implement changes and procedures to address
these issues; any proposed changes to address the material weakness. See Item 15 to this Amendment No. 1 for additional information on
such changes and on the material weakness.

Due to the existence of this
control deficiency, management concluded that there was a reasonable possibility that a material misstatement of the company’s
annual financial statements may not have been prevented or detected on a timely basis. If we cannot effectively and efficiently improve
our controls and procedures, we could suffer material misstatements in our financial statements and other information we report and fail
to meet our reporting obligations, which would likely cause investors to lose confidence in our reported financial and other information.
This could lead to a decline in the trading price of our ADSs.

 3) Amended Item 15- Controls and
                                            Procedures:

Disclosure Controls and Procedures

As of the end of the period covered by the Original
Form 20-F, our management, with the participation of our CEO and Managing Director and Executive Director and CFO, has carried out an
evaluation of the effectiveness of our disclosure controls and procedures, as defined in Rules 13a-15(e) or 15d-15(e) promulgated under
the Securities Exchange Act of 1934, as amended (the “Exchange Act”), on March 31, 2024 and concluded that our disclosure
controls and procedures were effective.

Subsequent to the evaluation of our disclosure
controls and procedures in connection with the Original Form 20-F, our management, with the participation of our CEO and Managing Director
and Executive Director and CFO, re-evaluated the effectiveness of our disclosure controls and procedures (as defined in Rules 13a-15(e)
and 15d-15(e)under the Exchange Act) as at March 31, 2024, in connection with the amendment in presentation discussed in the explanatory
note to this Amendment No.1. Based on that re-evaluation, our management, with the participation of our CEO and Managing Director and
Executive Director and CFO, concluded that our disclosure controls and procedures were not effective as at March 31 2024, due to the
material weakness in internal control over financial reporting as described below.

Management’s Annual Report on Internal Control
over Financial Reporting

 1) Our management is responsible for establishing
                                            and maintaining adequate internal control over financial reporting as defined in Rules 13a-15(f)
                                            and 15d-15(f) under the Exchange Act. Our internal control over financial reporting is a
                                            process to provide reasonable assurance regarding the reliability of financial reporting
                                            and the preparation of financial statements for external purposes in accordance with International
                                            Financial Reporting Standards, as issued by the International Accounting Standards Board.
                                            Our internal control over financial reporting includes those policies and procedures that:

 · pertain
                                            to the maintenance of records that, in reasonable detail, accurately and fairly reflect the
                                            transactions and dispositions of our assets.

 · provide
                                            reasonable assurance that transactions are recorded as necessary to permit preparation of
                                            financial statements in accordance with applicable accounting principles, and that our receipts
                                            and expenditures are being made only in accordance with authorizations of our management
                                            and directors; and

 · provide
                                            reasonable assurance regarding prevention or timely detection of unauthorized acquisition,
                                            use or disposition of our assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal
control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future
periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.

 2) Management assessed the effectiveness of our
                                            internal control over financial reporting as of March 31, 2024.

A material weakness is a control deficiency,
or combination of control deficiencies, that results in more than a remote likelihood that a material misstatement of the annual or interim
financial statements will not be prevented or detected. Management identified the following material weakness in internal control over
financial reporting as of March 31, 2024:

In connection with the amendment discussed
in the explanatory note to this Amendment No.1, we identified material weakness in our internal control over financial reporting with
respect to the design and implementation of effective controls to ensure the appropriate application of IFRS for reporting and presentation
of complex financial instruments. Because of this material weakness, management has concluded that the Company did not maintain effective
internal control over financial reporting as on March 31, 2024, based on criteria established in Internal Control — Integrated
Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission.

Management’s Plan to Remediate
the Identified Material Weakness

The Company proposes to implement the
below remediation actions to address this material weakness:

 · Strengthen
                                            the specific controls whereby senior finance and accounting policy personnel perform an in-depth
                                            comprehensive review of classification and presentation of financial instruments including
                                            a review of disclosures and specific presentation evaluation to enforce operating effectiveness.

 · Augment
                                            the IFRS expertise in our accounting team by imparting specific training in evaluation and
                                            presentation of financial instruments.

The Company’s internal control over
financial reporting as on March 31, 2024 has been audited by Manohar Chowdhry & Associates, an independent registered public accounting
firm, who also audited the Company’s consolidated financial statements. Their audit report, which expresses an adverse opinion
on the effectiveness of internal control over financial reporting, is presented below.

Changes in Internal Control Over Financial
Reporting

Except as described above in management’s annual
report on internal control over financial reporting (as amended), there has been no change in the Company’s internal control over
financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) that occurred during 2024, that has materially
affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.

 4) Explanation for Amendment under
                                            the heading “Amendment to Form 20-F for the year ended March 31, 2024” in Notes
                                            to Accounts-Item 18:

Sify Infinit Spaces Limited,
a subsidiary Company of Sify Technologies Limited had issued Compulsorily Convertible Debentures (‘CCDs’) to Kotak Special
Situation Fund and Kotak Data Center Fund for an amount of Rs.4,000 Mn and Rs.6,000 Mn respectively. The CCDs issued to Kotak Special
Situations Fund are backed by a Put Option Agreement with the holding Company M/s Sify Technologies Limited. These CCDs carry an obligation
to pay a fixed interest of 6% p.a.

The Company presented these
CCDs initially as Financial