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CORRESP
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April 26, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, NE

Washington, D.C. 20549

Attn: Scott Anderegg

Attn: Lilyanna Peyser

    Re:
    Innovative International Acquisition Corp.

    Registration Statement on Form S-4, as amended

    File No. 333-269627

Dear Mr. Anderegg and Ms. Peyser:

Innovative International Acquisition Corp., a Cayman Islands exempted
company (the “Company,” “we,” “our” or “us”), hereby transmits the Company’s response
to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
dated March 6, 2023, regarding the Company’s Registration Statement on Form S-4 filed with the Commission on February 7, 2023 (the
 “Registration Statement”). For the Staff’s convenience, we have repeated below each of the Staff’s comments in
bold and have followed such comment with the Company’s response. All page references in the responses set forth below refer to page
numbers in Amendment No. 1 to the Registration Statement (“Amendment No. 1”).

Registration Statement on Form S-4 filed February 7, 2023

Cover Page

1. We note that the Sponsor entered into a Sponsor Support
Agreement, pursuant to which the Sponsor agreed, among other things, to not to redeem or transfer any of the shares held by the
Sponsor. Please describe any consideration provided in exchange for this agreement.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure in Notice of Extraordinary General Meeting and on pages
137, 156 and 290 of Amendment No. 1.

2. We note your disclosure concerning the Ananda Trust Investment.
Please highlight material differences in the terms and price of securities issued at the time of the IPO as compared to the Ananda Trust
Investment.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on the cover page of Amendment No. 1.

Questions and Answers

What equity stake..., page 14

3. Please also disclose the total percentage ownership interest
to be held by the Sponsor, together with its affiliates, in the combined company assuming exercise and conversion of all securities, as
well as the total percentage ownership interest to be held by the executive officers and directors of New Zoomcar in the combined company
assuming exercise and conversion of all of the securities (in both cases in the event of no and full redemption of public shares).

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 14 and 15 of Amendment No. 1.

Do any of IOAC’s sponsor, directors or officers have interests...,
page 22

4. We note your disclosure here and elsewhere that the sponsor and
IOAC’s officers and directors will lose “their entire investment, an aggregate of $9,625,000, in IOAC if an initial business
combination is not completed by July 29, 2023 (or such later date as approved by IOAC’s shareholders).” Please revise to clarify
the nature of such investment of $9,625,000 (i.e., whether it includes some or all of the interests described in the other bullets in
this Answer, which such interests, etc.).

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 24, 25, 37 and 158 of Amendment No. 1.

5. Please revise your disclosure to also quantify the aggregate
value of all payments and reimbursements, including amounts due to the sponsor, officers and directors, and their affiliates under the
terms of these arrangements and agreements (in addition to your disclosure regarding individual amounts payable under such arrangements
and agreements).

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 25, 38 and 159 of Amendment No. 1.

Certain Other Benefits in the Business Combination, page 36

6. Please revise to also include the aggregate fees payable to
Cantor that are contingent on completion of the business combination for all services provided (in addition to your disclosure
regarding individual amounts payable to Cantor upon completion of the business combination).

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 39 and 160 of Amendment No. 1.

Comparative Per Share Information, page 46

7. The historical book value per share for IOAC as of September
30, 2022 and December 31, 2021 of $6.84 and $6.97 per share, respectively, appear to be incorrect as IOAC had negative shareholder’s
equity as of each of these dates. Please advise or revise as appropriate.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that the Company’s capital structure consists of Class A ordinary shares subject to redemption, which are classified as
temporary equity in the Company’s financial statements, as well as non-redeemable Class A ordinary shares and Class B ordinary shares
which are classified as permanent equity. We believe that historical book value should include both temporary equity and permanent equity,
which, combined, results in positive shareholder’s equity.

Risk Factors

There is a risk that a U.S. Holder..., page 101

8. Please expand this risk factor to describe any uncertainty regarding
whether the Domestication will qualify as a reorganization under Section 368(a). Also disclose whether the company will be considered
a PFIC and any uncertainty regarding whether it will be considered a PFIC.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 106 and 107 of Amendment No. 1.

The Merger Agreement, page 106

9. We note that IOAC’s charter waives the corporate opportunity
doctrine. In connection with your description of the business combination transaction, please address this possible conflict of interest
and assess whether the waiver impacted the IOAC’s search for an investment target. In addition, if applicable, please disclose whether
officers and directors have fiduciary or contractual obligations to other entities, and whether they and/or the Sponsor holds a financial
interest in the target company. If they do hold a financial interest in Zoomcar, disclose the value of the financial interest.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 25, 38, 113, 114 and 159 of Amendment No. 1.

Background of the Business Combination, page 107

10. We note your disclaimer, “[t]his chronology does not purport
to catalogue every conversation or correspondence among representatives of IOAC, Zoomcar, their respective representatives or any other
party.” Please be advised that, notwithstanding the inclusion of a disclaimer, you are responsible for considering whether additional
specific disclosures of material information are required to make the statements included in the filing not misleading. Please confirm
your understanding in this regard.

The Company respectfully acknowledges the Staff's comment and confirms
its understanding that, notwithstanding the inclusion of a disclaimer, we are responsible for considering whether additional specific
disclosures of material information are required to make the statements included in the filing not misleading.

Description of negotiation process with Zoomcar, page 110

11. We note your disclosure that “IOAC took several rounds
of discussions before proposing a term sheet.” Please revise to provide more details concerning these discussions. Please describe
the dates of phone calls or meetings and who attended the meetings, including whether the parties’ financial or legal advisors attended.
If the conversations concerned items that became deal points, for example an estimate of the deal size, include that information, as well.
Similarly, we note your disclosure,

“Between August 18, 2022 and October 12, 2022, representatives
of IOAC and Zoomcar met numerous times via video conference and telephone with representatives of Houlihan Capital to discuss such topics
as Zoomcar’s industry, financial performance, growth opportunities, competitive positioning and management team. In addition, representatives
of Houlihan Capital reviewed and analyzed documents and data provided in the online data room and held numerous discussions with IOAC’s
and Zoomcar’s management teams.” In this disclosure and throughout your discussion of the background of the business combination,
please detail the names and roles of the persons who attended meetings, and provide details of the matters discussed, document drafts
that were exchanged and agreements made. Please review your background disclosures and revise accordingly.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 115, 116 and 117 of Amendment No. 1.

Material U.S. Federal Income Tax Consequences of the Domestication
to IOAC Shareholders, page 155

12. Please expand your disclosure to state whether the company will
be considered a PFIC and discuss any uncertainty regarding whether the company will be considered a PFIC.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 163 and 164 of Amendment No. 1.

Unaudited Pro Forma Condensed Combined Financial Information

Unaudited Pro Forma Condensed Combined Statement of Operations

For The Nine Months Ended September 30, 2022, page 189

13. We note your Unaudited Pro Forma Condensed Combined Statement
of Operations includes the “unaudited and unreviewed statement of operations for Zoomcar for the three-months ended December 31,
2022.” Please note Rule 11-02(c)(2)(i) of Regulation S-X requires the inclusion of results “from the most recent fiscal year
end to the most recent interim date for which a balance sheet is required,” as such, inclusion of unaudited and unreviewed results
not included in the filing would not appear to be appropriate. Please advise, or revise accordingly.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that no unaudited or unreviewed amounts or financial statements are included in the pro-forma financial statements in Amendment
No. 1.

2) Adjustments to Unaudited Pro Forma Condensed Combined Statement
Operations, page 193

14. Refer to footnote (p) - Please explain in further detail the
significant assumptions that were used to calculate or determine this pro forma adjustment.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that footnote (p) in the original Registration Statement which became footnote (r) in the Amendment No. 1 relates to the amortization
of the tail D&O insurance expected to be put in place as of the closing of the Business Combination. In response to the Staff's comment,
the Company has revised such footnote on page 200 of Amendment No. 1 to include the period over which the D&O tail insurance is expected
to be amortized upon completion of the business combination.

Information About IOAC, page 195

15. When discussing total proceeds raised from IOAC’s IPO,
here and elsewhere throughout the filing including MD&A, please balance your disclosure with similar discussion from your prospectus,
that “IOAC shareholders holding 19,949,665 public shares exercised their right to redeem such shares” and “approximately
$206.5 million was removed from the Trust Account to pay such holders.”

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 112, 202 and 214 of Amendment No. 1.

Zoomcar Management’s Discussion and Analysis

Key business metrics

Booking Days, page 246

16. We note your discussion relating to the increase in booking
days during the 6 months ended September 30, 2022. Please provide similar discussion on the decline in booking days during Q3-22 as compared
to Q2-22.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on page 254 of Amendment No. 1.

Non-GAAP Financial Measures, page 254

17. Please revise to ensure financial statements and other data
read consistently from left to right in the same chronological order throughout the filing. For example, your non- GAAP measures and key
business metrics begin with the earliest period and end with the latest period while your consolidated financial statements and related
disclosures begin with the latest period and end with the earliest period. Refer to SAB Topic 11.E.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised to ensure financial statements and other data read consistently from
left to right in the same chronological order throughout Amendment No. 1.

Recent Accounting Pronouncements, page 261

18. The disclosures with respect to the required adoption dates
for certain recent accounting pronouncements provided on page 261 are inconsistent with those provided on pages F-57 and F-95 and F-96
of Zoomcar’s audited and interim financial statements. Please reconcile and revise these disclosures. Also, it appears that certain
of these recent pronouncements discussed on page 261 were adopted by Zoomcar during the six month period ended September 30, 2022. Please
revise your discussion on page 261 to discuss the impact of their adoption on Zoomcar’s consolidated financial statements.

The Company respectfully acknowledges the Staff's comment and advises
the Staff that, in response to the Staff's comment, it has revised the disclosure on pages 269 and 270 of Amendment No. 1. Following are
the updated paragraphs on pages 269 and 270, post which the disclosures are aligned with the disclosures on pages F-42, F-43, F-82 and
F-83:

 · In March 2020, the FASB issued ASU 2020-04, Reference Rate Reform (Topic 848), Facilitation of the Effects of Reference Rate Reform
on Financial Reporting, which provides optional expedients and exceptions to contract modifications and hedging relationships that reference
the London Interbank Offered Rate or another reference rate expected to be discontinued. The standard is effective upon issuance and may
be applied at the beginning of the interim period that includes March 12, 2020, through December 31, 2022. In January 2021, the FASB issued
ASU 2021-01,which clarified the scope of Topic 848 to include derivatives that are affected by a change in the interest rate used for
margining, discounting, or contract price alignment that do not also reference London Interbank Offered Rate or another reference rate
that is expected to be discontinued as a result of the reference rate reform. The standard is effective upon issuance and may be applied
retroactively as of any date from the beginning of an interim period that includes or is subsequent to March 12, 2020, or prospectively
to any new modifications within an interim period including or subsequent to January 7, 2021. The ASU did not have  any impact
on the Company’s Condensed consolidated financial statements as the Company did not have any transactions that would be impacted
by the aforementioned accounting pronouncement.

 · In August 2020, the FASB issued ASU 2020-06, Debt — Debt with Conversion and Other Options (Subtopic