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VIA EDGAR AND COURIER United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 U.S.A. Form 40-F for the Fiscal Year Ended March 31, 2012 Filed June 29, 2012 Comment Letter dated May 1st , 2013 File No. 001-34184

RE:

Dear Ms. Jenkins:

This letter is submitted on behalf of Silvercorp Metals Inc. (the “Company” or “we”) in response to the comments dated May 1, 2013 (the “Comment Letter”) with respect to the Company’s Annual Report on Form 40-F for the year ended March 31, 2012, which was filed on June 29, 2012 (the “Form 40-F”).

The text of the Comment Letter has been reproduced in this letter with each respective response. For your convenience we have italicized each comment.

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 production to correspond to your fiscal year end, or, provide additional disclosure such that readers are able to make this determination.

Response: We acknowledge your comments and we will provide an additional disclosure in our Annual Report on Form 40-F for the year ended March 31, 2013 (the “2013 Annual Report on Form 40-F”) that discloses reserves after depletion based on our fourth quarter production. For example, we will provide an additional table that reconciles the December 31 reserve balance (per NI 43-101 report) less fourth quarter production to equal a calculated reserve balance as at March 31.

2.

We note your response to our prior comment 6. Additionally we note that you include materials identified as currently inaccessible or non-viable in your mineral resource tabulation. Our understanding of a mineral resource as defined under Canadian National Instrument 43-101 is that mineral resources must have a reasonable likelihood of economic extraction. Please explain how this portion of your mineral resource has a reasonable likelihood of economic extraction.

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

United States Securities and Exchanage Commission

June 3rd, 2013

Page 2

Response: The Mineral Resources that are described as currently inaccessible or non-viable in the Mineral Resource tabulation have been excluded from conversion to Mineral Reserves because they have not yet been considered as part of a mine plan, and/or have insufficient total metal value to carry both operating and development access costs associated with their extraction. However, their location and grade/thickness are such that the Qualified Person deems them to have reasonable prospects for ultimate economic extraction, and that it would be premature at this stage to exclude them from future consideration for extraction.

Form 6-K filed May 23, 2012 Exhibit 99.2

Management’s Discussion and Analysis

4. Fiscal Year 2012 Operating Performance

(vi)

3.

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

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 production 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; however, 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 measures. Please amend your Form 40-F as appropriate.

Response: We acknowledge your comments and would like to respectfully clarify with the Staff our disclosure of production cost.

Our production costs are fully disclosed in our Management’s Discussion and Analysis (“MD&A”) as non-IFRS measures. Other than “Cash and Total Cost per Ounce of Silver”, we have also disclosed the following production costs on page 6 of our March 31, 2012 MD&A:

Cash and non-cash mining cost per tonne of ore mined;

Cash and non-cash milling cost per tonne of ore milled;

Unit shipping costs per tonne of ore;

Average production cost per ounce of silver;

Average production cost per ounce of gold;

Average production cost per pound of lead;

Average production cost per pound of zinc;

A replication of the section where these disclosures are found is provided for your convenience:

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

United States Securities and Exchanage Commission

June 3rd, 2013

Page 3

Fiscal 2012

Year ended March 31, 2012

Henan Luoning

Henan Songxian

YING

HPG&LM

TLP

XBG

XHP

BYP

Total

Mining cost per tonne of ore mined ($)

69.50

75.81

55.82

-

68.75

38.00

61.51

Cash mining cost per tonne of ore mined ($)

50.52

63.77

48.62

-

48.81

16.79

47.40

Non cash mining cost per tonne of ore mined ($)

18.98

12.04

7.20

-

19.95

21.21

14.11

Unit shipping costs($)

3.94

3.54

3.74

-

3.92

-

3.34

Milling cost per tonne of ore milled ($)

15.84

16.19

15.90

22.92

-

14.33

15.85

Cash milling cost per tonne of ore milled ($)

14.01

14.44

14.15

20.11

-

13.85

14.19

Non cash milling cost per tonne of ore milled ($)

1.83

1.75

1.75

2.81

-

0.48

1.66

Average Production Cost

Silver ($ per ounce)

4.80

9.79

13.00

6.17

-

7.14

Gold ($ per ounce)

-

-

Lead ($ per pound)

0.15

0.30

0.40

0.22

-

0.22

Zinc ($ per pound)

0.11

0.21

0.38

-

-

0.17

We respectfully submit that our disclosure of actual production costs has been proper and not materially distorted. Each of the non-IFRS measures provided are widely used in the precious metal sector as a tool for investors to measure and better understand the underlying cost structure of the Company.

The disclosure of “cash and non-cash mining costs per tonne,” “cash and non-cash milling costs per tonne,” and “unit shipping costs per tonne,” represents the Company’s total production cost per tonne of ore. This information allows the investors to understand the total cost of producing a tonne of ore.

The disclosure of “average production cost per quantity of metal” provides the underlying cost producing each quantity of metal.

The disclosure of “cash and total cost per ounce of silver” is only a supplemental disclosure to our actual production costs. This information represents the underlying cash cost of operations and the impact of non-silver revenues on the Company’s cost structure. We believe that the continued presentation of this non-IFRS measure will improve investors’ understanding of our financial statements by providing consistency and comparability.

For added clarity of our presented production costs, we will include a “non-IFRS measures” section to provide reconciliations of the aforementioned non-IFRS measures, in future filings, beginning with our 2013 Annual Report on Form 40-F: (1) Reconciliation of production costs (per tonne) to cost of sales:

(1)

Reconciliation of production costs (per tonne) to cost of sales:

Year ended March 31, 2013

Total costs ('000 US$)

Tonnage of ore1 (tonne)

Per tonne costs (USD/tonne)

Cash mining costs

XX

XXX

$XX

Non-cash mining costs

XX

XXX

XX

Shipping costs

XX

XXX

XX

Cash milling costs

XX

XXX

XX

Non-cash milling costs

XX

XXX

XX

Total

$XX

$XX

Add: stockpile and concentrate inventory - Beginning

XX

Less: stockpile and concentrate inventory - Ending

XX

Adjustment for foreign exchange movement

XX

Cost of sales

$XX

Tia L. Jenkins, Senior Assistant Chief Accountant Office of Beverages, Apparel, and Mining United States Securities and Exchange Commission June 3rd, 2013 Page 4

(2)

Reconciliation of average production cost per unit of metal to cost of sales:

Average Production Cost

Year ended March 31, 2013

(in 000's)

Direct mining and milling cost

$XX

Depreciation, amortization and depletion

XX

Inventory impairment

XX

Cost of sales

XX

Silver

Gold

Lead

Zinc

Total

Metals revenue

$XX

$XX

$XX

$XX

$XX

Ratio of metals sold

%

%

%

%

%

Cost of sales allocated to metals

$XX

$XX

$XX

$XX

$XX

Metals produced1

XX

XX

XX

XX

Average production cost ($/unit)

$XX

$XX

$XX

$XX

(3)

Reconciliation of total production cost and cash cost per ounce of silver (by-product included) to cost of sales:

Year ended March 31, 2013

Ying Mining

District

X Mines

Total

Cost of sales

$XX

$XX

$XX

By-product lead, zinc, and gold sales

XX

XX

XX

Total adjusted cost of sales

XX

XX

XX

Divided by thousands of silver ounces sold

XX

XX

XX

Total production cost per ounce of silver

$XX

$XX

$XX

Total adjusted cost of sales

$XX

$XX

$XX

Amortization and depletion

XX

XX

XX

Total adjusted cash cost

XX

XX

XX

Divided by thousands of silver ounces sold

XX

XX

XX

Total cash cost per ounce of silver

$XX

$XX

$XX

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 31, 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.

Response: The reconciliation between production numbers disclosed in our MD&A for the fiscal year ended March 31, 2011 to the Table 16.11 on the amended NI 43-101 is shown in Table 16 below. The reconciliations include:

A.

Conversion of fiscal year numbers to calendar year numbers. We started with production numbers for the 12-months ended March 31, 2011. From those numbers, we subtracted production numbers for the 9-months ended December 31, 2010 and added production numbers for the 9-months ended December 31, 2011 to obtain production numbers for the 12-months ended December 31, 2011.

B.

Moisture adjustment. We deducted moisture by 2% to 3%.

C.

Grouping adjustment. In our MD&A, the HPG and LM mines were grouped as HPG&LM. The Ying mine consisted of part of SGX, and the TLP mine included part of SGX, HZG and TLP.

Tia L. Jenkins, Senior Assistant Chief Accountant Office of Beverages, Apparel, and Mining United States Securities and Exchange Commission June 3rd, 2013 Page 5

Reconciliation of MD&A Production Numbers to NI 43-101

MD&A Data

Reconciliation

Adjusted MD&A Data

Revised NI 43-101 Data

MD&A Grouping

Unit

12 Months Ended Mar. 31, 2011

Fiscal to Calendar Year Adjustment (A)

Moisture Adjustment (B)

Grouping Adjustment (C)

12 Months Ended Dec. 31,

NI 43-101 Grouping

Less: 9 Months Ended Dec. 31,

Add: 9 Months Ended Dec. 31,

Ying

Tonnage

t

317,477

253,589

230,694

-8,423

121,953

408,112

408,112

SGX

Grade

Ag (g/t)

367.5

367.5

Pb (%)

8.1

8.1

8.4

6.7

6.7

Zn (%)

2.8

2.8

2.3

2.2

2.2

Tonnage

t

45,788

45,788

45,788

HZG

Grade

Ag (g/t)

216.0

216.0

Pb (%)

0.9

0.9

Zn (%)

0.0

0.0

TLP

Tonnage

t

204,780

153,917

225,833

-8,409

-167,741

100,546

100,546

TLP

Grade

Ag (g/t)

135.1

106.0

106.0

Pb (%)

2.5

2.1

2.5

2.9

2.9

Zn (%)

0.8

1.8

0.7

0.0

0.0

HPG&LM

Tonnage

t

74,478

53,764

73,958

-2,209

-49,871

42,592

42,592

HPG

Grade

Ag (g/t)

229.3

112.6

112.6

Pb (%)

4.1

1.8

3.6

5.8

5.8

Zn (%)

0.6

0.6

0.5

1.0

1.0

Tonnage

t

49,871

49,871

49,871

LM

Grade

Ag (g/t)

313.0

313.0

Pb (%)

2.0

2.0

Zn (%)

0.0

0.0

Total Ying Mining District

Tonnage

t

596,735

461,270

530,485

-19,041

646,909

646,909

Total Ying Mining District

Ag (g/t)

316.0

322.8

289.6

295.0

295.0

Grade

Pb (%)

5.7

5.8

5.2

5.3

5.3

Zn (%)

1.9

1.9

1.4

1.5

1.5

Exhibit 99.3 Financial Statements

Notes to Financial Statements

1. Significant Accounting Policies

(f)

Revenue Recognition, page 8

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.).

Response: The revenues from the non-silver sales are included in “Sales” in the Consolidated Statement of Income in the consolidated financial statements. For added clarity of consolidated financial statements, we propose the following revenue recognition policy:

Tia L. Jenkins, Senior Assistant Chief Accountant Office of Beverages, Apparel, and Mining United States Securities and Exchange Commission June 3rd, 2013 Page 6

“Sales of all metals products, which are contained in direct smelting ore or concentrates, are recognized as revenue. Revenue is recognized when the significant risks and rewards of ownership have passed to the buyer, it is probable that economic benefits associated with the transaction will flow to the Company, the sale price can be measured reliably, the Company has no significant continuing involvement and the costs incurred or to be incurred in respect of the transaction can be measured reliably.

These conditions for revenue are satisfied when the title passes to the customer. The passing of title to the customer is based on the terms of the sales contract, which is generally upon shipment of the products. Product pricing is determined at the point revenue is recognized by reference to active and freely traded commodity markets. Under the Company’s concentrate sales contracts with third-party smelters, final commodity prices are set on a specified quotation period, typically ranging from ten to fifteen days around shipment date.”

k) Mineral Rights and Properties, page 9

6.

We note your response to our prior comment 15. It appears to us that obtaining a mining permit does not sufficiently meet the requirement that you have demonstrated