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United
States Securities and Exchange Commission

Division
of Corporation Finance Office of Life Sciences

Washington,
D.C. 20549

ATTN:
Ibolya Ignat

February
6, 2024

Re:
Earth Science Tech, Inc.

Form
10-K for the fiscal year ended March 31, 2023

Filed
June 20, 2023

File
No. 000-55000

Dear
Ms. Ignat,

Please
accept the following as Earth Science Tech, Inc.’s (“ETST”) response to your comments in correspondence dated January
12, 2024.

Form
10-K for the Fiscal Year Ended March 31, 2023

Report
of Independent Registered Public Accounting Firm, page 18

1. Please
                                            amend your filing to include revised audit reports covering the audits of the years ended
                                            March 31, 2023, and March 31, 2022, and confirm to us that you obtained signed reports for
                                            both years ended March 31, 2023 and March 31, 2022 at the time of the filing. Refer to Rule
                                            8-02 of Regulation S-X. In your amended report,

 ● clarify
the name of your independent auditor, stated as Bolko & Company on page F-1, but Bolko CPA on page 20. We note that in your Item
4.01 8-K dated August 15, 2023, amended on August 16, 2023 you state that you engaged Bolko & Associates, LLC as your auditor.

 ● please
                                            have your auditor sign their audit report utilizing the same name as is registered with the
                                            PCAOB.

 ● assure
                                            that the audit opinion complies with the section title requirement in paragraph .08
of PCAOB AS 3101, and with the title and paragraph position requirements in paragraph .12 of AS 2415.

 ● clarify
                                            why the audit report does not refer to the audit of consolidated financial statements, and
                                            ask the auditor to correct as appropriate.

 ● explain
                                            the reason why the audit report includes references to financial highlights.

In
amending your filing, please assure that the report includes the entirety of Item 8, and appropriate updated certifications that refer
to the Form 10-K/A.

Response:

ETST
is in the process of preparing the amended Form 10-K for the fiscal year ended March 31, 2023. In coordination with our auditor, R. Bolko,
CPA P.A., we have reviewed the incorrect language and format utilized in the audit report. Included in the amended filing is the revised
audit report prepared by R. Bolko, CPA PA with registration number 6554. The revised audit report includes the required corrections as
to the following:

 ● reference
                                            to the audit of consolidated financial statements

 ● removal
                                            of all references to the use of language as to “financial highlights”

 ● compliance
                                            with title requirements as outlined in paragraph .08 of PCAOB AS 3101

 ● required
                                            formatting of title and paragraph position as outlined in paragraph .12 of AS 2415

In
discussion with our auditor, the above referenced errors were identified as an oversight in the review process as the report was finalized
by the auditor.

ETST
made a diligent search through all known physical documents received from prior management and all known digital records, but ETST was
unable to find a signed audit report for the fiscal year ended March 31, 2022. In addition to the diligent search, ETST reached out to
its former auditor to request that they provide one if one was in their possession. ETST received no response. ETST requested a signed
audit report for the fiscal year that ended March 31, 2023, but R. Bolko, CPA PA did not provide a signed copy, though the firm was cooperative
with other matters related to these SEC comments. In light of the foregoing, management has put in place a new policy to ensure that
ETST complies with its record keeping obligations in the future. However, ETST is in possession of an electronically signed audit report
from each auditor that was sent to ETST by each respective auditor.

2. We
                                            note that among the PCAOB registered firms we could not find a firm registered under the
                                            name of Bolko & Company. An entity listed as R, Bolko, CPA P.A. is the successor of Bolko
                                            & Associates LLC., and is listed with the registration status “Withdrawal Pending.”
                                            Pursuant to Section 102 of the Sarbanes-Oxley Act and PCAOB Rule 2100, all public accounting
                                            firms that prepare or issue audit reports with respect to any issuer, as defined, must register
                                            with the PCAOB. While a withdrawal request is pending, the firm may not thereafter engage
                                            in the preparation or issuance of an audit report for any such issuer. See PCAOB Rule 2107.
                                            Please clarify the status of your auditor at the time the audit report included in your annual
                                            report was issued to you, and tell us how you believe the financial statements in your filings
                                            are in compliance with the applicable rules. Please address this comment as applicable to
                                            Bolko & Company’s audit report dated December 22, 2022 regarding its audit of the
                                            financial statements of Peaks Curative, LLC, and Bolko & Company’s audit report
                                            dated February 3, 2023 regarding its audit of the financial statements for RXcompoundstore.com,
                                            LLC. Please be as detailed as necessary in your explanation.

Response:

Prior
to January 1, 2022, R. Bolko, CPA PA, was Bolko and Associates, LLC. To keep references consistent, we have changed every instance of
a reference to ETST’s auditor to “R. Bolko, CPA PA”

In
relation to the status of the auditor, R. Bolko, CPA, PA did not elect to withdraw from the PCAOB until October 17, 2023, which is after
any date relevant to the preparation or issuance of the annual audit report dated July 19, 2023, for Earth Science Tech. The audit reports
regarding R. Bolko, CPA PA’s audits of the financial statements of Peaks Curative, LLC, dated December 22, 2022, and RxCompoundstore.com,
LLC, dated February 3, 2023, were completed many months before R. Bolko, CPA PA elected to withdraw from the PCAOB.

3. Given
                                            that your Item 4.01 Form 8-K/A dated August 16, 2022, did not clearly disclose this information,
                                            please tell us whether your former auditor resigned, declined to stand for reelection or
                                            was dismissed. Tell us the date your relationship with your former auditor officially ended.
                                            Refer to Item 304(a)(1)(i) of Regulation S-K.

Response:

The
former auditor, BF Borgers, CPA PC was dismissed on August 8, 2022, in favor of engaging R. Bolko, CPA, P.A. as the new auditor.

Item
9A. Controls and Procedures Disclosure Controls and Procedures, page 20

4. We
                                            note that you have disclosed that your Chief Executive Officer (CEO) and Chief Financial
                                            Officer (CFO) carried out an evaluation of the effectiveness of the design and operation
                                            of your disclosure controls and procedures; however, you have not provided any conclusions
                                            regarding the effectiveness of disclosure controls and procedures in your annual report.
                                            Please revise your filing to disclose the conclusions that have been formulated by your CEO
                                            and CFO regarding the effectiveness of your disclosure controls and procedures as of March
                                            31, 2023.

 Response:

In
review of the work performed by management, including the Chief Executive Officer and Chief Financial Officer, the conclusion was formulated
regarding the effectiveness of our disclosure controls and procedures and omitted in error from the original filing. The amended filing
of the Form 10-K will contain the following conclusion:

 ● The
                                            Company’s management, including the Chief Executive Officer and Chief Financial Officer
                                            have reviewed and evaluated the effectiveness of the Company’s design and operations
                                            of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) promulgated
                                            under the Exchange Act) as of the end of the period covered by this annual Report on Form
                                            10-K/A. Based on that review and evaluation, the Chief Executive Officer and Chief Financial
                                            Officer have concluded that as of the end of the period covered by this Amended Annual Report,
                                            the Company’s disclosure controls and procedures were not effective as of March 31,
                                            2023 (the “Evaluation Date”), in ensuring that (i) information required to be
                                            disclosed by us in reports that we file or submit to the SEC under the Exchange Act is recorded,
                                            processed, summarized and reported within the time periods specified in applicable rules
                                            and forms and (ii) material information required to be disclosed in our reports filed under
                                            the Exchange Act is accumulated and communicated to our management, including our Chief Executive
                                            Officer and Chief Financial Officer, as appropriate, to allow for accurate and timely decisions
                                            regarding required disclosure.

Management’s
Annual Report on Internal Control Over Financial Reporting, page 20

5. Please
                                            clarify your statement that in performing an evaluation of the effectiveness of your internal
                                            control over financial reporting as of March 31, 2023, management used the criteria “established
                                            in Internal Control-Integrated Framework issued by the board members”, since we do
                                            not recognize the framework you listed. It appears that your management should have used
                                            the criteria established in the Committee of Sponsoring Organization of the Treadway Commission
                                            (COSO) Internal Control - Integrated Framework (2013). Please refer to Item 308(a)(2) of
                                            Regulation S-K. In light of the disclosure irregularities noted in our comments, please reassess
                                            your conclusions regarding disclosure controls and procedures and internal controls over
                                            financial reporting as of March 31, 2023, and revise your filing to reflect the results of
                                            your reassessments.

Response:

The
reference to the criteria “established in Internal Control-Integrated Framework issued by the board members” was made in
error. After reassessing our conclusions regarding internal controls over financial reporting, we determined that management actually
used the criteria set forth by the Committee of Sponsoring Organization of the Treadway Commission (COSO) Internal Control – Integrated
Framework (2013). The related conclusions regarding ineffective controls are now included. In addition, subsequent to the filing date
of the 10-K, ETST has created new positions to segregate duties consistent with control objectives and has increased our personnel resources
and technical accounting expertise within the accounting function. Additionally, ETST now has a total of 5 directors, 2 of whom are independent,
who will undertake the oversight in the establishment and monitoring of required internal controls and procedures, such as reviewing
and approving estimates and assumptions made by management. As such, the amended filing of the Form 10-K for the fiscal year ended March
31, 2023, will contain the following correction and conclusion on Management’s Annual Report on Internal Control Over Financial
Reporting:

Management’s
Annual Report on Internal Control Over Financial Reporting

Our
disclosure controls and procedures contain components of our internal controls over financial reporting. Our management is responsible
for establishing and maintaining adequate internal control over financial reporting. Internal control over financial reporting is defined
in Rule 13a-15(f) or 15d-15(f) promulgated under the Exchange Act as a process designed by, or under the supervision of, the Company’s
principal executive and financial officer and effected by the Company’s board of directors, management and other personnel, to
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external
purposes in accordance with generally accepted accounting principles and includes those policies and procedures that:

 ● Pertain
                                            to the maintenance of records that in reasonable detail accurately and fairly reflect the
                                            transactions and dispositions of the assets of the Company;

 ● Provide
                                            reasonable assurance that transactions are recorded as necessary to permit preparation of
                                            financial statements in accordance with generally accepted accounting principles, and that
                                            receipts and expenditures of the Company are being made only in accordance with authorizations
                                            of management and directors of the Company; and

 ● Provide
                                            reasonable assurance regarding prevention or timely detection of unauthorized acquisition,
                                            use or disposition of the Company’s assets that could have a material effect on the
                                            financial statements.

The
Company’s management assessed the effectiveness of the Company’s internal control over financial reporting as of the
Evaluation Date. In making this assessment, the Company’s management used the criteria set forth by the Committee of
Sponsoring Organizations of the Treadway Commission (“COSO”) Internal Control-Integrated Framework (2013). The COSO
framework is based upon five integrated components of control: control environment, risk assessment, control activities, information
and communications and ongoing monitoring. Based on an evaluation u