SecProbe.io

May 1 , 2013

Via E -Mail
Dr. Rui Feng
Chief Executive Officer
Silvercorp Metals, Inc.
Suite 1378 -200 Granville Street
Vancouver, BC Canada  V6C 154

Re: Silvercorp Metals, Inc.
 Form 40-F for Fiscal Year Ended March 31, 2012
Filed June 29, 2012
Response dated April 12, 2013
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 d o 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  commen ts, we may have  additional comments.

Form 40 -F

Exhibit 99.1

Item 5 Mineral Properties , page 27

1. We note your response to our prior comment 2 .  Please explain to us  if you are able to
deplete your disclosed reserves by your fourth quarter pr oduction to correspond to your
fiscal year end, or, provide additional disclosure such that readers are able to make this
determination.

2. We note your response to our prior comment 6 .  Additionally we note that you include
materials identified as currentl y inaccessible or non -viable in your mineral resource
tabulation.  Our understanding of a mineral resource as defined under Canadian National

Dr. Rui Feng
Silvercorp Metals Inc.
May 1 , 2013
Page 2

 Instrument 43 -101 is that mineral resources must have a reasonable likelihood of
economic extraction.  Please expl ain how this portion of your mineral resource has a
reasonable likelihood of economic extraction.

Form 6 -K filed May 23, 2012

Exhibit 99.2

Management’s Discussion and Analysis

4. Fiscal Year 2012 Operating Performance

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

3. We have read your response to our prior comment 9.   We note you present the non -IFRS
measures of total production cost per ounce of silver of $(3.25) and cash cost per ounce
of Silver of $(5.13), both computed by deducting by -product lead, zinc and gold sales
(the “non -IFRS measures”).   In calculating these non -IFRS measures, we believe the
reduction for by -product revenues is not appropriate because it materially distorts your
actual prod uction costs.   In this regard, your presentation suggests you incurred no
mining costs for silver, which in actuality is not the case.   We can appreciate your desire
to convey the notion that by -product revenues were sufficient to offset your costs;
howeve r, you should consider describing that in a manner so as to avoid presenting the
non-IFRS measures.   We believe the significance of by -product revenues can be
described textually in a manner that investors can understand without presenting the non -
IFRS mea sures.   Please amend your Form 40 -F as appropriate.

4. We note your response to our prior comment 11 .  Considering production data, moisture
content, and other factors please supplementally provide a detailed reconciliation of the
fiscal year ended March 3 1, 2011 production numbers disclosed in your MD&A to the
revised chart provided in your response.  Please provide for each mine or group of mines
to correspond to your MD&A.

Exhibit 99.3

Financial Statements

Notes to Financial Statements

1. Significant Accounting Policies

(f) Revenue Recognition, page 8

Dr. Rui Feng
Silvercorp Metals Inc.
May 1 , 2013
Page 3

 5. We note your response to our prior comment 14.   Your response did not address our
comment in its entirety, thus the comment will be partially reissued.   Please disclose in
future filings , including any amendment to this Form 40 -F, how you account for and
classify the income from the non -silver sales. Your disclosure should  include how you
account for these products (i.e. by -product accounting or co -product accounting etc.).

k) Mineral Rights and Properties, page 9

6. We note your response to our prio r comment 15.  It appears to us that  obtaining a mining
permit  does not sufficiently meet  the requirement that you have demonstrated technical
feasibility and commercial viability.  Please  revise you r accounting policy  in your
amended Form 40 -F or show us how you  determined that  have demonstrated technical
feasibility and commercial viability prio r to obtaining a mining permit and how your
accounting policy is appropriate.

28.  Transition to IFRS, pa ge 39

7. We note your response to our prior comment 28  did not fully address the mandatory
exceptions applied upon the adoption of IFRS.  Please specifically address how you
applied the mandatory exception as outli ned in paragraph 14 of IFRS 1 in your amende d
Form 40 -F.

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 Securities 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.

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/ Brian K. Bhandari for

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