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SAG
Holdings Limited

14
Ang Mo Kio Street 63

Singapore
569116

January
26, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Thomas Jones

    Re:
    SAG
    Holdings Limited

    Amendment
    No. 10 to Registration Statement on Form F-1

    Filed
    January 18, 2024

    File
    No. 333-267771

Ladies
and Gentlemen:

By
letter dated January 25, 2024, the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
provided SAG Holdings Limited (the “Company”) with comments on the Company’s Registration Statement on Form F-1, described
above. This letter contains the Company’s responses to the Staff’s comments. Concurrently herewith, the Company is filing
Amendment No. 11 to the Registration Statement on Form F-1.

Amendment
No. 10 to Registration Statement on Form F-1

Compensation
of Executive Directors and Executive Officers, page 85

    1.
    Revise
    to update this discussion for the fiscal year ended December 31, 2023, consistent with Item 6.B. of Form 20-F. This comment also
    applies to your related party transaction disclosure on page 88. Refer to Item 7.B. of Form 20-F.

We
have made the amendment on page 85 to be responsive to the Commission’s comment regarding updated compensation disclosure
for the year ended 2023. We respectfully advise the Staff that we are not able to provide more current information
as relates to related party transactions at this time. Our accounting staff and auditors will be preparing such information in the coming
weeks, but we do not expect it to be finalized prior to April 1, 2024.

Index
to Audited Consolidated Financial Statements, page F-1

    2.
    Please
    update your financial statements in accordance with Item 8.A.4 of Form 20-F or include the representation noted in Instruction 2
    to Item 8.A.4 of Form 20-F as an exhibit to your registration statement.

We
have filed a new Exhibit 99.2 to be responsive to the Commission’s comment.

If
you have any questions regarding this response, please direct them to our counsel David Ficksman at 310-789-1290 or dficksman@troygould.com
or Joilene Wood at 415-305-4651 or jwood@troygould.com.

    Sincerely,

    SAG
    Holdings Limited

    /s/
    Jimmy Neo

    By:

    Jimmy
    Neo

    Chief
    Executive Officer & Executive Director

    cc:
    David
    L. Ficksman

    R.
    Joilene Wood