SecProbe.io

CORRESP
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SOLOWIN
HOLDINGS

1910-1912A,
Tower 3, China Hong Kong City

33
Canton Road, Tsim Sha Tsui, Kowloon

Hong
Kong

June
15, 2023

Via
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

    Attn:
    Shannon Davis

    John Spitz

    Robert Arzonetti

    Susan Block

    Re:

    Solowin Holdings

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

    Filed May 22, 2023

    File No. 333-271525

Ladies
and Gentlemen:

We
hereby submit the response of Solowin Holdings (the “Company”) to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated June
7, 2023, providing the Staff’s comments with respect to the Company’s Amendment No. 1 to Registration Statement on Form F-1
filed on May 22, 2023. Concurrently with the submission of this letter, the Company is filing the Amendment No. 2 to the Registration
Statement on Form F-1 (the “Amendment No. 2”) together with certain exhibits via EDGAR with the Commission.

Unless
the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company
on a consolidated basis.

Amendment
No. 1 to the Registration Statement on Form F-1 filed May 22, 2023

General

1. We
                                            note that you list a number of contracts in the exhibit index in the section entitled “Item
                                            8. Exhibits and Financial Statement Schedules,” for instance, Exhibit Nos. 10.3 through
                                            10.8. Please describe your material contracts under “Business,” at page 72, as
                                            applicable. See Part I, Items 4(B) and 10(C) of Form 20-F.

RESPONSE:
In response to the Staff’s comment, we have described Exhibits 10.3 through 10.7 under the section of “Business”
and Exhibit 10.8 under the section of “Related Party Transaction.” To correct certain clerical errors, we also refiled Exhibits
10.3 and 10.5 with the Amendment No. 2.

If
you would like to discuss the response or if you would like to discuss any other matters, please contact the undersigned at (852)3428-3893
or Kevin Sun of Bevilacqua PLLC at (202) 869-0888 (ext. 101).

    Sincerely,

    SOLOWIN HOLDINGS

    By:
    /s/ Shing Tak Tam

    Name:
    Shing Tak Tam

    Title:
    Chief Executive Officer

    cc:
    Kevin Sun, Esq., Bevilacqua PLLC

    Michael J. Blankenship, Esq., Winston & Strawn
    LLP