SEC Comment Letter for Kyto Technology & Life Science, Inc. (CIK 0001164888) — Feb 2, 2022
Kyto Technology & Life Science, Inc. (CIK 0001164888)
Date: Feb. 2, 2022 · CIK: 0001164888 · Accession: 0000000000-22-001345
AI Filing Summary & Sentiment
File numbers found in text: 000-50390
Letter
United States securities and exchange commission logo February 2, 2022 Simon Westbrook Chief Financial Officer Kyto Technology & Life Science, Inc. 13050 La Paloma Road Los Altos Hills, CA 94022 Re:Kyto Technology & Life Science, Inc. Form 10-K for the fiscal year ended March 31, 2021 Filed August 10, 2021 File Number 000-50390 Dear Mr. Westbrook: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the fiscal year ended March 31, 2021 Cover page 1.Please confirm you will update the cover page in future filings to include the most recent version required by the Form 10-K. Notes to the Financial Statements Note 1 Nature of Business and Summary of Significant Accounting Policies (L) Basis of Accounting and Recent Accounting Pronouncements, page F-16 2.You state that in March 2020, you adopted Topic 946. Please address the following: •Provide us an analysis of how you meet the criteria to report under ASC 946. Specifically address ASC 946-10-15-5 through 15-9 and ASC 946-10-55. •We note that the Form 10-K for the year ended March 31, 2020 stated the company was complying with ASC 946, but the financial statements included a Balance Sheet and Statement of Shareholders' Equity instead of a Statement of Assets and Liabilities
FirstName LastNameSimon Westbrook Comapany NameKyto Technology & Life Science, Inc. February 2, 2022 Page 2 FirstName LastName Simon Westbrook Kyto Technology & Life Science, Inc. February 2, 2022 Page 2 and Statement of Changes in Net Assets. Those financial statements have been revised in the current 10-K with the auditor's opinion changed to reflect the new financial statements included in the current 10-K. Please tell us why the change did not result in a restatement with the disclosures required by ASC 250. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Mary Mast at 202-551-3613 or Li Xiao at 202-551-4391 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
February 2, 2022
Simon Westbrook
Chief Financial Officer
Kyto Technology & Life Science, Inc.
13050 La Paloma Road
Los Altos Hills, CA 94022
Re:Kyto Technology & Life Science, Inc.
Form 10-K for the fiscal year ended March 31, 2021
Filed August 10, 2021
File Number 000-50390
Dear Mr. Westbrook:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the fiscal year ended March 31, 2021
Cover page
1.Please confirm you will update the cover page in future filings to include the most recent
version required by the Form 10-K.
Notes to the Financial Statements
Note 1 Nature of Business and Summary of Significant Accounting Policies
(L) Basis of Accounting and Recent Accounting Pronouncements, page F-16
2.You state that in March 2020, you adopted Topic 946. Please address the following:
•Provide us an analysis of how you meet the criteria to report under ASC 946.
Specifically address ASC 946-10-15-5 through 15-9 and ASC 946-10-55.
•We note that the Form 10-K for the year ended March 31, 2020 stated the company
was complying with ASC 946, but the financial statements included a Balance Sheet
and Statement of Shareholders' Equity instead of a Statement of Assets and Liabilities
FirstName LastNameSimon Westbrook
Comapany NameKyto Technology & Life Science, Inc.
February 2, 2022 Page 2
FirstName LastName
Simon Westbrook
Kyto Technology & Life Science, Inc.
February 2, 2022
Page 2
and Statement of Changes in Net Assets. Those financial statements have been
revised in the current 10-K with the auditor's opinion changed to reflect the new
financial statements included in the current 10-K. Please tell us why the change did
not result in a restatement with the disclosures required by ASC 250.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Mary Mast at 202-551-3613 or Li Xiao at 202-551-4391 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences