SecProbe.io

March 21 , 2013

Via E -Mail
Dr. Rui Feng
Chief Executive Officer
Silvercorp Metals, Inc.
Suite 1378 -200 Granville Street
Vancouver, BC Canada  V6C 1S 4

Re: Silvercorp Metals, Inc.
 Form 40-F for Fiscal Year Ended March 31, 2012
Filed June 29, 2012
File No. 001 -34184

Dear Dr. Feng :

We have reviewed your filing an d 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 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 comments, we may have  additional comments.

Form 40 -F for Fiscal Year Ended March 31, 2012

1. We note that Exhibits 99.2 and 99.3 , which relate to the Audited Annual Financial
Statements and Management’s Discussion and Analysis, respectively, are incorporated by
reference to a Form 6 -K submitted on May 23, 2012 .  General Instructions B(5) to Form
40-F requires information incorporated by reference, that was not previously filed with
the Commission, to be attached as an exhibit and filed with th e Form 40 -F.  Information
submitted on Form 6 -K is considered furnished but not filed.   Please refer to General
Instruction B to Form 6 -K.  Accordingly, please amend your Form 40 -F to attach and file
your Audited Annual Financial Statements and Management’ s Discussion and Analysis
as exhibits.

Dr. Rui Feng
Silvercorp Metals Inc.
March 21 , 2013
Page 2

 Exhibit 99.1
Item 5 Mineral Properties , page 27

2. In future filings please disclose your mineral reserves and mineral resources to
correspond  to your fiscal year end.

3. In future filings please clarify if your mineral resources and mineral reserves are reported
on a one hundred percent basis or  according to your attributable ownership.

4. We note you disclose mineral resources on your company website that are not disclosed
in your annual filing.  In future filings  please disclose mineral resource s and mineral
reserve s for all properties .

5. Please explain to us why the cu t-off grade for your SGX mineral reserve is lower than the
resource cut -off grade.

6. Considering dilution, losses, recoveries, and any other factor used to convert your
mineral resources to mineral reserves, please provide a detailed reconciliation of your
SGX mineral resources and reserves.

7. Please explain the decrease in you r SGX measured mineral resource grade.  In this regard
we note your disclosu re of 430 g/t as compared to the 845 g/t disclosed in your 40 -F
filing for the fiscal year ended March 31, 2011 and filed on June 3, 2011.

Form 6 -K filed May 23, 2012
Exhibit 99.2
Management’s Discussion and Analysis
4. Fiscal Year 2012 Operating Performa nce

(vi) Cash and Total Cost per Ounce of Silver (Gold for the BYP mine), page 4

8. We note you present here non -IFRS me asures:  (a) total production cost per ounce of
silver and  (b) cash cost per ounce of s ilver.  Tell us whether the se measures  are used in
the industry and how your computation of th ese measures  is comparable to other
companies’ computation of th ese measures .

9. We note you present here the non-IFRS measures  of total produ ction cost per ounce of
silver of $(3. 25) and cash cost per ounce of s ilver $(5.13) computed by deducting by -
product lead, zinc and gold sales.  Tell us : (a) the purpose of such measures , (b) how they
are used by management,  (c) how the presentation of negative cost per ounce is useful to
investors , and (d) how such presentatio n is appropriate.

Dr. Rui Feng
Silvercorp Metals Inc.
March 21 , 2013
Page 3

 (vii) Operation Review, page 6

10. We note your disclosure here of mining cost per tonne, milling cost per tonne and
average production cost per ounce.  To enhance an investor ’s understanding of your
business, provide us with , and confirm that in future filings you will include for all
periods presented , (a) the computation of each cost measure,  (b) a reconcil iation of each
cost measure  per unit to the cost of sales , and (c) the methodology used in the
computation  of costs per unit.

11. It appears that the tonnes and grade of ore milled for the year ended March 31, 2011 for
the Ying, HPG & LM, and TLP operations do not correspond to the tonnage and grade
figures presented in your technical report.  In this regard we reference page 118 of your
technical report for the Ying Gold -Silver -Lead -Zinc Property, Henan Province, China
prepared by AMC Consultants and dated May 1, 2012.  Please tell us why these numbers
are different.  In your response please also address any differences betwee n the 2009 and
2010 production numbers disclosed in your technical report as compared to previous
numbers disclosed in filings with the United States Securities and Exchange Commission.

12. In connection with the comment 11 above, please explain to us in det ail (i) which
production  tonnage values were utilized to calculate depletion in your financial
statements for each period presented and (ii) how the discrepancies in tonnes and grade of
ore milled and production numbers  noted in the above comment affected your financial
statements for the periods presented.

Exhibit 99.3
Financial Statements
Notes to Financial Statements
2.  Significant Accounting Policies

(a) Statement of Compliance, page 6

13. We note your disclosure that the policies applied to your fina ncial statements are based
on IFRS effective as of the date the Board of Directors approved these financial
statements for issue or May 16, 2012.  Please clarify for us whether you selected IFRS
accounting policies from IFRS effective at the end of the fir st IFRS reporting period and
applied those consistently for the years ended March 31, 2012 and 2011 and the opening
balance sheet on April 1, 2010.  Refer to IFRS 1 paragraphs 7 and 8.

Dr. Rui Feng
Silvercorp Metals Inc.
March 21 , 2013
Page 4

 (f) Revenue Recognition, page 8

14. We note sales of gold, lead and  zinc represent 5%, 26% and 4% of your total sales ,
respectively, for the fiscal year ended March 31, 2012.  T ell us  and disclose in future
filings how you account for an d classify the income from non -silver sales . In addition,
please revise Management’s Discussion and Analysis of future filings  to include the
following:  (a) whether you expect historic trends of your non -silver revenue to continue
and (b ) discussion of the factors th at have a n effect  on the amount of revenue from non-
silver sales (i.e. commodity prices  etc.).

k) Mineral Rights and Properties, page 9

15. We note that you capitalize development costs at the earlier of establishing proven and
probable reserves or obtaining a mining permit.  The staff believes that mining co sts
typically are not determined to be economically recoverable until proven and probable
reserves have been established.  Please explain to  us your basis for capitalizing costs at an
earlier point, i.e., obtaining a mining permit.

25.  Segmented Inform ation

(c)   Sales by Metal , page 36

16. We note you disclose  total sales for each mine. To enhance an investor ’s understanding
of your business , please provide us with , and confirm that you will include in future
filings , the amount of revenues derived from silver, gold, lead and z inc on a mine -by-
mine basis for  each of the periods presented.

28.  Transition to IFRS, page 39

17. We note that you do not address the mandatory exceptions, as set forth in paragraphs 14-
17 and Appendix B of IFRS 1,  which you applied upon the adoption of IFRS. To the
extent that your primary financial statements reflect the use of mandatory exceptions,
please identify for us the items or class of items to which the exceptions were applied and
describe the accounting principle that was used and how it was applied. In addition and to
the extent material, also qualitatively describe for us the impact on the financial
condition, changes in financial condition and results of operations that the treatment
specified by IFRS would have had absent these mandatory exceptions. Refer to paragraph
23 of IFRS 1.

Dr. Rui Feng
Silvercorp Metals Inc.
March 21 , 2013
Page 5

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securit ies 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 disclosure 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 initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jamie Kessel, Staff Accountant, at 202 -551-3727 or Raj Rajan, Senior
Staff Accountant, at 202 -551-3388 if you have questions regarding comments on the financial
statements and related matters.  Please contact John Coleman with any engineering questions at
202-551-3610.   .

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining