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CORRESP
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Skillful
Craftsman Education Technology Ltd

February
20, 2024

CORRESPONDENCE
FILING VIA EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Office of Trade and Services

Ms.
Amy Geddes

Mr.
Stephen Kim

    Re:

    Skillful
    Craftsman Education Technology Ltd.

    Amendment
    No.1 to Form 20-F for the Year Ended March 31, 2023

    Filed
    August 17, 2023

    File
    No. 001-39360

Dear
Ms. Geddes and Mr. Kim:

This
letter is being submitted by Skillful Craftsman Education Technology Ltd (the “Company”) in response to the comments received
from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) in the letter dated February
7, 2024 (the “Letter”) regarding the Company’s annual report on Form 20-F for the year ended March 31, 2023.

The
numbered paragraphs below correspond to certain numbered comments in the Letter. The Staff’s comments are presented in bold.

Amendment
No. 1 to Form 20-F for Fiscal Year Ended March 31, 2023

Item 5. Operating and Financial Review and Prospects

5.B.
Liquidity and Capital Resources

Statement of Cash Flows

Year
Ended March 31, 2023 as Compared to Year Ended March 31, 2022

Net Cash Generated from Financing Activities, page 90

1. Your
                                            presentations in the table here, the table on page 89, and on the face of the statement of
                                            cash flow indicates net cash generated from financing activities of $1,000,000. Please reconcile
                                            these presentations with the narrative discussion here that net cash generated from financing
                                            activities was $0.2 million for the year ended March 31, 2023. As a related matter, if the
                                            $0.8 million repayment of long-term loan from Fujian Xinqiao was made during the year, please
                                            tell us how it was presented in your statement of cash flow. Finally, please ensure the columns
                                            in the table are labeled correctly.

Response:
The narrative discussion on page 90 should be “For the year ended March 31, 2023, we had a cash inflow from financing activities
of $1.0 million which was all from the proceeds of convertible bond.” The table on page 89 was consistent with the audited statement
of cash flow.

The
$0.8 million repayment of interest over long-term loan from Fujian Xinqiao was made during the fiscal year ended March 31, 2023, and
it was presented in operating cash flow. The change of interest payable was zero as the beginning and ending balance were the same of
$0.2 million. The Company accrued the interest payable for the amount of $0.8 million and paid $0.8 million during the fiscal year of
2023.

2. We
                                            note from the discussion of the Xinqiao Loan Agreement on page 113 that cash provided by
                                            financing activities in fiscal 2022 of $14,809,302 is provided entirely through this loan
                                            agreement, and that this loan agreement was amended in August 2023, to clarify the use of
                                            the loan, which should be used for the construction of a maritime food vocational training
                                            school and will encompass various specialized areas including deep- sea fisheries crew training,
                                            nearshore aquaculture training, water product supply chain management, water product branding,
                                            hotel and restaurant management, and other related industry talent cultivation, as well as
                                            business expansion and investment within the relevant industry. Please tell us your progress
                                            to date on this project, and how you considered the stipulations on the use of proceeds of
                                            this loan in determining presentation in your balance sheet.

Response:
In the second half of 2021, based on the market environment in China, the Company decided to expand into in person vocational training
school area. At the same time, Fujian Pingtan Ocean Fishery Group Co., Ltd. (“Pingtan”) also wanted to expand its business
from traditional deep-sea fishing business to marine aquaculture, aquatic product deep processing, real estate, hotels and tourism industries.
After multiple rounds of discussion, the parties felt they could leverage existing online course system and teaching resources of Wuxi
Kingway Technology Co., Ltd.(“Wuxi Kingway”), the operating VIE of the Company and local fishing industry network and resources
of Pingtan Ocean in Fujian Province to jointly build a training institution to train workers of Pingtan Ocean and also provide training
services to other fishery companies in Fujian Province which has a large fishing industry along its coastal line.

In
order to fund the potential joint venture project, Wuxi Kingway negotiated a loan from Fujian Xinqiao for $14,809,302. The loan agreement
was signed on January 8, 2022 and stated that the funds were to be used to build a marine food vocational training school, which includes
training of offshore fishery seafarers, nearshore aquaculture, water product supply chain management, water product branding, hotel and
catering management, and other professional talent development.

After
Wuxi Kingway entered the loan agreement with Xinqiao, Pingtan Ocean proposed to Wuxi Kingway to further deepen parties’ relationship
and have Wuxi Kingway Technology directly own certain equity interest in Pingtan Ocean instead of incorporating a new joint venture company.
Because of Pingtan Ocean’s business scale, good reputation, ability to generate revenue and profit and extensive businesses in
China and Southeast Asian region, the Company believes that directly holding certain equity interest of Pingtan Ocean will help Company
expand its training and related business in Southeast Asia and bring long term return for the Company. Therefore, after the deliberation
and approval by the board of directors, the Company agreed to acquire 3% equity interest of Pingtan Ocean for $14,809,302 in cash to
become a minority shareholder of Pingtan Ocean.

Because
the use of proceeds of the loan was slightly different from the original agreement, Wuxi Kingway discussed the actual use of funds with
Xinqiao and parties agreed to revise the loan agreement to add the purpose of the loan “as well as business expansion and investment
within the relevant industry.”

Due
to the outbreak of COVID-19 pandemic and strict control measures in China during 2022, the expansion of business and related projects
were all put on hold. The business operations of Pingtan Ocean in China were also greatly and negatively affected. The Company continued
to explore the new business opportunities with Pingtan Ocean, including nursing homes and training services in Southeast Asia.

In
August 2023, Le First Skilland Pte. Ltd., the Company’s subsidiary in Singapore, established a strategic cooperation relationship
with Singapore Parkway College of Nursing and Allied Health Pte. which will train Chinese nurses to gain international nursery experience
by working in Singapore hospitals and nursing homes, so that they can not only ease the nurse shortage in Singapore but also gain experience
for Chinese nurses and improve the quality of elderly care services after their returning to China. Pingtan Ocean has also begun to renovate
several of its existing buildings into nursing homes. Due to the quota restrictions for Chinese nurses and caregivers in Singapore as
well as time for language training, this business is currently progressing slowly but steady.

The
Company’s business cooperation with Pingtan Ocean in other Southeast Asian regions is also actively being planned, and we will
make timely disclosures according to the development of these cooperation.

Consolidated
Financial Statements

Notes
to Consolidated Financial Statements

9.
Long-term investment, page F-25

3. We
                                            note from your disclosure here that in January 2022 you entered an agreement to purchase
                                            a 3% share of Fujian Pingtan Ocean Fishery Group Co., Ltd. for total consideration of $14,809,302
                                            (RMB 94,012,410). Please tell us how you funded the consideration and how this transaction
                                            is related to the Xinqiao Loan Agreement in the amount of $14,809,302 (RMB 94,012,410).

Response:
please see our responses to the comment 2 above.

If
you have further comments, please feel free to contact our counsel Jeffrey Li at Jeffrey.li@fisherbroyles.com or by telephone at (703)
618-2503.

    Very
truly yours,

    /s/
    Dawei Chen

    Dawei
    Chen, Chief Financial Officer

Enclosures

    cc:
    Jeffrey
    Li

    FisherBroyles,
LLP