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SAG
Holdings Limited

14
Ang Mo Kio Street 63

Singapore
569116

September
26, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Washington,
D.C. 20549

Attention:
Scott Anderegg

    Re:
    SAG
    Holdings Limited

    Amendment
    No. 20 to Registration Statement on Form F-1

    File
    No. 333-267771

Ladies
and Gentlemen:

SAG
Holdings Limited (the “Company”) has submitted the Company’s Amendment No. 21 to Registration Statement on Form F-1
today to respond to the comment of the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter
dated September 26, 2024 with respect to the Company’s Registration Statement, as noted above. The text of the Staff’s comment
is set forth below, followed by the Company’s response.

Amendment
No. 20 to Registration Statement on Form F-1

General

  1.
  Please refer to Exhibit 5.1. Please have company counsel
revise the legal opinion to cover the registered public offering and resale offering. In this regard, we note that most recent legal
opinion dated June 14, 2023 is dated and doesn’t cover the current offerings and specifically the resale offerings. Please revise
as applicable.

We
have filed an updated Exhibit 5.1 that covers the current offerings and resale offerings.

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