SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

                                                               October 13, 2011
 Via Facsimile

Mr. John B. Selvaraj Principal Accounting Officer India Globalization Capital, Inc. 4336  Montgomery Ave.   Bethesda, Maryland 20814
RE: India Globalization Capital, Inc.
Form 10-K for the Year Ended March 31, 2011 Filed July 14, 2011 Definitive Proxy Statement on Schedule 14A  Filed August 1, 2011 File No. 1-32830

Dear Mr. Selvaraj:

We have reviewed your response letter da ted September 13, 2011 and have the following
comments.  Please respond to this letter with in ten business days by amending your filing or by
advising us when you will file the amendment.  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 the amendment to your fili ng and the information you provide in response to
these comments, we may have additional comments.
 Form 10-K for the Year Ended March 31, 2011

 Financial Statements

 Consolidated Balance Sheet, page F-2

 1. We note your response to comment five from our letter dated August 11, 2011 as well as Exhibit I
– Revised Balance Sheet.  Please revise your stockhol ders’ equity section to provide a subtotal for
India Globalization Capital, Inc’ s (i.e. parent’s) equity.  Re fer to ASC 810-10-45-16 and 810-10-
55-4I for guidance.
 Note 2 – Summary of Significant Accounting Policies, page F-10

 j) Accounts Receivable, page F-12

 2. We note your response to comment 10 from our letter dated August 11, 2011.  You indicate that
the $2.37 million accounts receivable  due from the National Highway Authority of India (“NHAI”)

Mr. John B. Selvaraj
India Globalization Capital, Inc. October 13, 2011 Page 2
 and the Cochin International Airport can take as long as two to three years to collect.  It therefore
appears that this receivable should be classified as long-term as of March 31, 2011 and 2010.
Please revise accordingly.
 Note 19 – Deconsolidation, page F-25

 Note 25 – Impairment, page F-28

 3. We note your response to comment 12 from our letter dated August 11, 2011 and have the
following additional comments.
 Given the significance of Sricon as it related to  your March 31, 2010 financial statements, we
continue to believe that the a udited financial statements were necessary and appropriate for
your investors.  Please expand your  proposed risk factor disclosu res to clarify such audited
financial statements were not available when  you filed your March 31, 2010 Form 10-K.  See
Note 5 to Rule 8-01 of Regulation S-X;
 You indicate that substantial por tions of your assets are invest ed in Sricon and you may be
unable to obtain sufficient financial informati on to accurately value your investment.  Please
revise your disclosure to  indicate that you currently do not ha ve sufficient financial information
and the lack of such financial statements may impact your ability to accurately value your
investment.  This risk factor disclosure shoul d be included in the foot notes to your financial
statements as well;
 Please ensure that the disclosures in your fina ncial statements include detailed information
similar to the information you provided in your supplemental response to comment 12 from our
letter dated August 11, 2011;
  Please ensure that your disclo sure identifies the Sricon fina ncial information you relied on
(e.g., December 31, 2009 unaudited balance sheet pr epared in accordance with Indian GAAP);
and
 Specifically disclose the valuat ion methodology used to determin e the recoverability of your
receivable and investment in Sricon as of March 31, 2011 and 2010.
 You may contact Ernest Greene, Staff Acc ountant at (202) 551-3733 or Jeanne Baker,
Assistant Chief Accountant at (202) 551-3691 if you have questions  regarding these comments.

       S i n c e r e l y ,
         / s /  R u f u s  D e c k e r           R u f u s  D e c k e r
       Accounting Branch Chief