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CORRESP

 May 9, 2023

 VIA EDGAR

 Robert Arzonetti

 Securities and Exchange Commission

 Division of Corporation Finance

 Office of Finance

100 F Street, NE

 Washington, D.C. 20549-3561

Re:
 Vahanna Tech Edge Acquisition I Corp.

Registration Statement on Form S-4

Filed February 13, 2023

File 333-269747

Dear Mr. Arzonetti:

 On behalf of Vahanna
Tech Edge Acquisition I Corp. (the “Company”), please find responses to the comments of the staff of the Securities and Exchange Commission (the “Staff”) contained in the Staff’s letter dated March 16, 2023 (the
“Comment Letter”) with regard to the Registration Statement on Form S-4 (File No. 333-269747) filed by the Company on February 14, 2023 (the
“Registration Statement”). The responses are based on information provided to us by the Company. Capitalized terms used but not defined herein have the respective meanings ascribed to them in the Registration Statement.

Set forth below in italics are the comments contained in the Comment Letter. Immediately below each of the Staff’s comments is the
Company’s response to such comment. For the convenience of the Staff’s review, each of the numbered paragraphs below correspond to the numbered comment in the Comment Letter.

The Company is concurrently providing to the Commission Amendment No. 1 to the Registration Statement, as filed on EDGAR on the date
hereof (“Amendment No. 1”).

 Questions and Answers

How do Redemption Affect the Value of My New Roadzen Ordinary Shares, page xiv

1.
 Please revise to disclose all possible sources and extent of dilution that shareholders who elect not to
redeem their shares may experience in connection with the business combination. Provide disclosure of the impact of each significant source of dilution, including the amount of equity held by founders, convertible securities, including warrants
retained by redeeming shareholders, at each of the redemption levels detailed in your sensitivity analysis, including any needed assumptions.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it has revised the disclosure on
pages xvi, xviii and 17 accordingly.

2.
 Please quantify the value of warrants, based on recent trading prices, that may be retained by redeeming
stockholders assuming maximum redemptions and identify any material resulting risks.

 May 9, 2023

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 Response: The Company acknowledges the Staff’s comment and respectfully advises
the Staff that it has revised the disclosure on pages xvii and xviii accordingly.

 Information about the Parties to the Business Combination, page 1

3.
 Please revise to disclose the fiscal year-end for New Roadzen
post-merger for financial reporting purposes.

 Response: The Company acknowledges the Staff’s comment,
confirms that the fiscal year end for New Roadzen post-merger for financial reporting purposes will be March 31st and has revised the disclosure on page 2 accordingly.

Summary, page 1

4.
 Please revise to clarify the timing and factors to be considered in considering whether the registrant will
remain a BVI company or redomicile to Delaware.

 Response: The Company acknowledges the Staff’s comment
and respectfully advises the Staff that the Company has revised pages 2 and 3 accordingly.

5.
 Please clarify if the sponsor and its affiliates can earn a positive rate of return on their
investment, even if other SPAC shareholders experience a negative rate of return in the post-business combination company.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised page 5
accordingly.

 Organizational Structure, page 14

6.
 Please revise your diagrams illustrating the anticipated structure of Vahanna just prior to the consummation
of the merger on page 14 and the diagram illustrating the expected structure of Vahanna upon consummation of the merger on page 16 to show the relative ownership of voting and economic interests of each group of shareholders.

 Response: The Company acknowledges the Staff’s comment and has revised the diagrams on pages 14 and 16
accordingly.

 A substantial portion of our revenue is derived from a relatively small number of clients ranging from insurers, reinsurers, OEMs,
and, page 37

7.
 You disclose on page 37 that a small number of clients have accounted for a significant portion of your
revenue, including on OEM customer that accounted for more than 25% of total revenue from the Indian market. If material, identify any material customer and provide additional disclosure describing the terms of your relationship with any such
customer including any contractual or other arrangements that are in place to the extent material so that shareholders may better assess the reliability of these revenues. If any such contract exists, please explain to us in your response letter why
you determined it was not required to be filed as an exhibit pursuant to Item 601(b)(10) of Regulation S-K.

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 Response: The Company acknowledges the Staff’s comment and respectfully advises
the Staff that it has revised page 35 to clarify that Roadzen had one customer (an automotive insurance provider) that represented approximately 25% and 10%, respectively, of total revenue for the fiscal year ended March 31, 2022 and the nine
months ended December 31, 2022. The Company has also revised page 35 to clarify that Roadzen does not anticipate the insurer representing a material portion of its revenue for the fiscal year ended March 31, 2023, nor on a consolidated
basis after it acquires GIM and NAC. Accordingly, Roadzen has not filed the contract with the insurer as an exhibit. However, the Company respectfully advises the Staff that Roadzen has included disclosure of the material terms of the arrangement on
page 155.

 Vahanna may redeem your unexpired warrants prior to their exercise at a time that is disadvantageous to you, thereby making your
warrants, page 87

8.
 Please clarify whether recent common stock trading prices exceed the threshold that would allow you to
redeem public warrants. Additionally, please explain the steps, if any, you will take to notify all shareholders, including beneficial owners, regarding when the warrants become eligible for redemption.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised pages 87
and 88 accordingly.

 Unaudited Pro Forma Combined Financial Information, page 105

9.
 We note that your pro forma combined financial information presents the combination of financial information
of Vahanna and Roadzen after giving effect to the reverse recapitalization between Roadzen and Vahanna, Roadzen’s assumed acquisitions of Global Insurance Management Limited (“GIM”) and National Automobile Club (“NAC”), and
the contemplated PIPE investment. We also note your disclosure on page 50 that the acquisitions of GIM and NAC are expected to be completed prior to the closing of the merger. In order to more accurately represent the sequence of these transactions,
and to more clearly show the impact of each of these transactions, please revise your pro forma combined financial information beginning on page 109 to present the assumed acquisitions of GIM and NAC separately from the reverse recapitalization and
contemplated PIPE investment. For instance, please revise your filing to present your pro forma combined financial information in a columnar format in the following order:

•

 historical financial statements of Roadzen,

•

 historical financial statements of GIM,

•

 historical financial statements of NAC,

•

 transaction accounting adjustments for the acquisitions of GIM and NAC,

•

 pro forma combined Roadzen, GIM and NAC,

•

 historical financial statements of Vahanna,

•

 transaction accounting adjustments for the reverse recapitalization assuming minimum redemptions,

•

 pro forma combined assuming minimum redemption,

•

 additional pro forma adjustments for the reverse recapitalization assuming maximum redemptions, and

•

 pro forma combined assuming maximum redemptions.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it has revised the pro forma
combined financial information on pages 109 through 111 accordingly.

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 Description of the Transactions, page 106

10.
 We note your reference here, and in other sections of your filing, to the PIPE investment which is expected
to close just prior to the completion of the merger. We also note disclosure on page 286 that this PIPE investment is contemplated prior to the merger and the actual amount may be greater or less than the target amount of $58.9 million. Please
revise the relevant sections of your filing to clarify whether you have any committed PIPE investment amounts and whether the amount of the PIPE investment is dependent upon Vahanna Public Shareholder redemptions.

Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it has revised the disclosure
throughout Amendment No. 1 to clarify that the discussion of the PIPE Investment is prospective and that, because no PIPE Investment has been committed by investors, the actual PIPE Investment amount may be more or less than the revised
targeted amount of $54.7 million. Revised disclosure may be found on pages iv, xvi, 17, 106 and 113.

 The Company will include
appropriate disclosure regarding PIPE Investments in subsequent amendments to the Registration Statement if the parties enter into any definitive agreements, and any such additional disclosure will describe any investor relationships with the
Company, the Sponsor, or Roadzen, Inc. and their respective directors (or the participation thereof in the PIPE Investment), officers and affiliates, the material terms of the PIPE Investment, and any material differences in terms and pricing as
compared to the securities offered in connection with the Company’s IPO. In addition, the sensitivity tables will be updated when the final PIPE Investments have been determined.

11.
 Please revise your disclosure describing the acquisition of GIM to include the US dollar equivalent of the
total purchase price.

 Response: The Company acknowledges the Staff’s comment and has revised the
disclosure on pages 106, 144 and 171 accordingly.

 Basis of Pro Forma Presentation, page 107

12.
 We note your use of terminology such as directly attributable, factually supportable and expected to have a
continuing impact when describing your pro forma adjustments. Please note that Article 11 of Regulation S-X was amended by SEC Release No. 33-10786,
which revised the pro forma terminology and the basis for pro forma adjustments. Please revise your pro forma discussion to conform to the updated guidance.

Response: The Company acknowledges the Staff’s comment and has revised the Basis of Pro Forma Presentation section beginning on
page 107 as per SEC Release No. 33-10786.

 Transaction Adjustments, page 114

13.
 We note adjustment F, which reflects the fair value adjustment for the purchases of GIM and NAC. Please
revise to disclose the date of each of these historical amounts and corresponding fair value adjustments. In addition, please tell us why there are no fair value adjustments for accounts receivable, net for both GIM and NAC.

 Response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that it has
revised adjustment F on page 113 accordingly. Accounts Receivables, net are short-term, non-interest bearing, and have low credit risk. Accordingly, the Company has not reflected any fair value adjustments
because it does not foresee any credit risk and loss in fair value on acquisition of these receivables.

14.
 Please revise the explanation to adjustment F that cash and cash equivalents represents historical amounts
adjusted for distributions to refer to adjustment D rather than adjustment E.

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 Response: The Company acknowledges the Staff’s comment and respectfully advises
the Staff that it has revised the disclosure on page 113 accordingly.

15.
 We note that the explanation of adjustment J, which states it represents the issuance of 68.3 million
shares of the Company’s common stock to Roadzen equity holders as consideration for the reverse recapitalization, does not appear to correlate with the corresponding adjustments to the unaudited pro forma condensed combined balance sheet on
page 109. Please explain and revise as necessary.

 Response: The Company acknowledges the Staff’s
comment and respectfully advises the Staff that it has revised the disclosure on page 113 accordingly

 Information about Roadzen, page 141

16.
 Please revise here and Summary to provide an overview of Roadzen, Global Insurance Management and National
Automobile Club as well as the planned operations and relative sizes and geographic locations of the different lines of business. Your revised disclosure throughout the proxy statement/prospectus should clarify what you are referring to when you use
“we” and reference separate businesses. As a non-exclusive example, on page 73 you refer to “a portion of our business” when it appears you are referring to Roadzen without GIM and NAC. As
the acquisitions of GIM and NAC are conditions to closing of the merger agreement, the narrative disclosure should explain clearly the nature of the target in the combined deSPAC transaction for which pro forma financial information is provided.

 Response: The Company acknowledges the Staff’s comment and has revised the disclosures on pages 144 through
146 and pages 171 and 172 accordingly.

17.
 Additionally, revise here, Summary, Business, and Management’s Discussion and Analysis to
clarify the business intended to be conducted after the deSPAC transaction. For example, clarify the type of end customers who use the combined company’s key products and their geographic locations. We note the
following:

•

 You use the term “telematics” but do not explain its use or the extent to which telematics is
involved in a material portion of your revenues and products and services generating revenues from end-users;

•

 We note the statement on page 149 that your platform allows you to sell insurance policies “from any
insurer.” Clarify the extent to which you require and have uniform or custom agreements with all insurance companies.

•

 Clarify the approximate percentages of customers that are insurance providers and reinsurance providers.

•

 Disclose the extent to which revenues from traditional insurance brokerage services, your platform or IaaS
solution or other products and services account for the majority of your expenses and revenues. In this regard, we note the statement on page 158 that Roadzen generates “a majority of our revenues through commissions and fees which are a
reflection of the total insurance policy premium.”

•

 Explain whether the event management companies acquired by Coverzen and referenced on pages F-65 and F-98 will be a continuing part of your business.

•

 Clarify the approximate amount of revenues attributed to “underwriting solutions” and telematics,
claims management, and FNOL. State whether any highlighted offering does not account for a material amount of revenues or expenses.

•

 Address the challenges of operating in the US, UK/EU and India as a newly merged business, and summarize how
the company intends to structure the businesses—for example, as independently operating subsidiaries in different countries, as combined operations with a centralized headquarters in India, or otherwise.

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 Response: The Company acknowledges the Staff’s comment and has revised the
disclosure to clarify the business intended to be conducted after the deSPAC transaction, including the type of end customers who use the combin