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CORRESP
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 Alpha Technology Group Ltd

 Unit No.08 on the 25th Floor of Nanyang Plaza,
No. 57 Hung To Road

 Kwun Tong, Kowloon, Hong Kong

 April 2, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Technology

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Anastasia Kaluzienski

 Robert Littlepage

 Jan Woo

 Re: Alpha Technology Group Ltd (the " Company ")

 Form 20-F for the Year Ended
September 30, 2024

 Filed January 27, 2025

 File No. 001-41847

 Dear Sir or Madam:

 This letter sets forth the Company's
responses to the comments contained in the letter dated March 19, 2025 from the staff (the " Staff ") of the
Securities and Exchange Commission (the " Commission ") regarding the Company's annual report on Form 20-F
for the fiscal year ended September 30, 2024 filed with the Commission on January 27, 2025 (the " Form 20-F "). The
Staff's comments are repeated below and followed by the Company's responses thereto. All references in the responses
refer to the relevant revisions in the draft Amendment No. 1 to the Form 20-F (the " Form 20-F/A ") attached hereto as Exhibit A .

 Form 20-F for the Fiscal Year Ended September 30, 2024

 Risk Factors

 You may incur additional costs and procedural obstacles..., page
35

 1. We note your disclosure that most of your directors and executive officers are Hong Kong nationals or
residents and a substantial portion of their assets are located in Hong Kong outside of the United States. Please identify any directors,
officers, or members of senior management located in the PRC/Hong Kong. Additionally, please include a separate "Enforceability"
section that addresses whether or not investors may bring actions under civil liability provisions of the U.S. federal securities laws
against you, your officers or directors who are residents of a foreign country, and whether investors may enforce these civil liability
provisions when your assets, officers, and directors are located outside of the United States.

 Response : In response to the Staff's
comment, the Company has revised its disclosure on pages 45 and 46 of the Form 20-F/A.

 Business Overview, page 48

 2. We note that revenue from your AI-OCR software accounted for 6.5% of your total revenue in fiscal year
2024 but your website appears to be focused on your AI technology. For example, you state that you are the "first Hong Kong-based
AI company listed on Nasdaq…[and you] focus on AI-related technologies with ERP systems to provide AI driven automation processes…[and
your] AI solution helps businesses manage communications with AI." We also note public statements that the company uses LLM applications
to create AI solutions for businesses and governments. Please discuss the full scope of AI services that the company offers and clarify
whether they encompass more than the AI-OCR software. Discuss the risk and uncertainties related to providing these AI services. Further,
explain whether management envisions AI becoming a growing part of the company's business offerings and if so, disclose the timeline for
such development.

 Response : In response to the Staff's
comment, the Company has revised its disclosure on pages 14 and 47 of the Form 20-F/A.

 Results of Operations, page 65

 3. We note your aggregation of the results of operations of the successor and predecessor periods for the
fiscal year ended September 30, 2023. Please note that it is generally inappropriate to combine financial information for predecessor
and successor periods for purposes of MD&A discussion as the financial statements are prepared on different bases of accounting and
are therefore not comparable. In this regard, please revise your results of operations discussion to separately present and discuss the
historical results of your predecessor and successor or explain to us how your presentation complies with Item 303 of Regulation S-K.
To the extent you include a supplemental comparative discussion of the results prepared on a pro forma basis for the relevant pro forma
period, it should reflect all relevant pro forma adjustments in accordance with Article 11 of Regulation S-X and disclosure should be
provided to explain how the pro forma presentation was derived, why you believe the presentation to be useful, and any potential risks
associated with using such a presentation.

 Response :
In response to the Staff's comment, the Company has revised its disclosure in the section headed "Results of Operations"
beginning on page 63 of the Form 20-F/A.

 Consolidated Statements of Operations and Comprehensive Loss, page
F-5

 4. Please explain to us your basis in GAAP for presenting the results of operations for the year ended September
30, 2023 on a basis that combines the predecessor operating results from October 1, 2022 to October 11, 2022 with the successor operating
results from October 12, 2022 to September 30, 2023.

 Response :
In response to the Staff's comment, the Company has revised its disclosure on page F-5 of the Form 20-F/A.

 5. Please revise the tabular presentations in your Statements of Operation and Comprehensive Loss and your
Statements of Cash Flows, as well as presentation elsewhere in your filing such as in the discussion of your results of operations beginning
on page 65, so that your financial statements and other data presented in tabular form to read consistently from left to right in the
same chronological order throughout the filing. We refer you to the guidance in SAB Topic 11:E.

 Response :
In response to the Staff's comment, the Company has revised its disclosure throughout the Form 20-F/A.

 2

 Financial Statements

 Note 1. Organization and Principle Activities, page F-8

 6. We note you disclosed "[o]n October 12, 2022, Alpha acquired 100 % of equity interest in NSL and
TSL from the former shareholders." In light of this disclosure, please clarify and explain to us the meaning of your disclosure under
Recent Developments on page F-8. In this regard, we note you said "[t]he subsidiaries of Alpha were under the control of different
ultimate owners immediately following their acquisition by Alpha. Although, after the acquisition, NSL and TSL became whollyowned subsidiaries
of Alpha, the two acquired companies did not operate under common control as their ultimate owners had been different." In addition,
explain to us and disclose when you obtained control of the subsidiaries, how you obtained control, and why you began reporting the results
of operations beginning on October 12, 2022 as the Successor results of operations.

 Response : In response to the Staff's
comment, the Company has revised its disclosure on page F-8 of the Form 20-F/A. On October 10, 2022, the Company entered into a sale and
purchase agreement with Mr. Leung Tsz Him and his spouse (the " Sellers "), pursuant to which the Sellers agreed to sell
and the Company agreed to purchase 100% of the ownership interests in NSL and TSL for a consideration of HK$10 million. Completion took
place on October 12, 2022. Given that NSL and TSL became wholly-owned subsidiaries of the Company upon completion, the Company began reporting
the results of operations beginning on October 12, 2022 as the Successor results of operations.

 Thank you for your consideration
in reviewing the above responses. If you have any questions or wish to discuss any aspect of the Form 20-F/A, please contact the undersigned
at (852) 9049-8795.

 Sincerely,

 /s/ Choi Tan Yee

 Choi Tan Yee

 Executive Director and Chief Financial Officer

 3

 Exhibit A

 UNITED STATES

 SECURITIES AND EXCHANGE COMMISSION

 WASHINGTON, D.C. 20549

 FORM 20-F

 (Amendment No. 1)

 ☐ REGISTRATION
STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934

 OR

 ☒ ANNUAL
REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 For the fiscal year ended September 30, 2024

 OR

 ☐ TRANSITION
REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 OR

 ☐ SHELL
COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 Date of event requiring this shell company report

 For the transition period from ________ to ________

 Commission file number: 001-41847

 Alpha Technology Group Ltd

 (Exact name of Registrant as specified in its charter)

 N/A

 (Translation of Registrant's name into English)

 British Virgin Islands

 (Jurisdiction of incorporation or organization)

 Unit No.08 on the 25th Floor of Nanyang Plaza,
No. 57 Hung To Road

 Kwun Tong, Kowloon, Hong Kong

 (Address of principal executive offices)

 Mr. Anthony Tsang

 Telephone: + 852 6028 9378

 Email: anthony8668@gmail.com

 At the address of the Company set forth above

 (Name, Telephone, E-mail and/or Facsimile number
and Address of Company Contact Person)

 Securities registered or to be registered pursuant
to Section 12(b) of the Act.

 Title of each class

 Trading Symbol(s)

 Name of each exchange on which registered

 Class A ordinary shares, par value $0.0001 per share

 ATGL

 The Nasdaq Stock Market LLC

 Securities registered or to be registered pursuant
to Section 12(g) of the Act.

 None

 (Title of Class)

 Securities for which there is a reporting obligation
pursuant to Section 15(d) of the Act.

 None

 (Title of Class)

 Indicate the number of outstanding shares of each
of the issuer's classes of capital or common stock as of the close of the period covered by the annual report.

 An aggregate of 15,262,500 Ordinary
Shares, par value $0.0001 per share, as of September 30, 2024.

 Indicate by check mark if the registrant is a
well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

 Yes ☐ No ☒

 If this report is an annual or transition report,
indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange
Act of 1934.

 Yes ☐ No ☒

 Note - Checking the box above will not relieve
any registrant required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 from their obligations
under those Sections.

 Indicate by check mark whether the registrant
(1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the
preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject
to such filing requirements for the past 90 days.

 Yes ☒
No ☐

 Indicate by check mark whether the registrant
has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405
of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

 Yes ☒
No ☐

 Indicate by check mark whether the registrant
is a large accelerated filer, an accelerated filer, a non-accelerated filer, or an emerging growth company. See definition of "large
accelerated filer," "accelerated filer," and "emerging growth company" in Rule 12b-2 of the Exchange
Act.

 Large accelerated filer
 ☐

 Accelerated filer
 ☐

 Non-accelerated filer
 ☒

 Emerging growth company
 ☒

 If an emerging growth company that prepares its
financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not to use the extended transition
period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange
Act. ☐

 * The term "new or revised financial accounting standard"
refers to any update issued by the Financial Accounting Standards Board to its Accounting Standards Codification after April 5, 2012.

 Indicate by check mark whether the registrant
has filed a report on and attestation to its management's assessment of the effectiveness of its internal control over financial
reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared
or issued its audit report. ☐

 If securities are registered pursuant to Section
12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction
of an error to previously issued financial statements. ☐

 Indicate by check mark whether any of those error
corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant's
executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

 Indicate by check mark which basis of accounting
the registrant has used to prepare the financial statements included in this filing:

 U.S. GAAP ☒
 International Financial Reporting Standards as issued by the
International Accounting Standards Board ☐
 Other ☐

 * If "Other" has been checked in response to the previous
question, indicate by check mark which financial statement item the registrant has elected to follow. Item 17 ☐
Item 18 ☐

 If this is an annual report, indicate by check
mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No ☒

 EXPLANATORY NOTE

 This Amendment No. 1 on Form 20-F/A (the " Amendment
No. 1 ") amends the annual report on Form 20-F of Alpha Technology Group Ltd (the " Company " or " we ")
for the year ended September 30, 2024 (the " 2024 Form 20-F "), filed on January 27, 2025, with the Securities and Exchange
Commission (the " SEC ").

 This Amendment No. 1 restates certain disclosures
of the 2024 Form 20-F in response to a comment letter to the Company from the staff of the SEC dated March 19, 2025 and is being filed
solely to make the following modifications or updates:

 · Item 3. Key Information

 We have included a separate section titled
"Enforceability of Civil Liabilities" to address the difficulty of bringing actions against the Company's officers and
directors who are located outside of the United States and enforcing judgments against them, and provided additional disclosure regarding
the risk related to our AI services.

 · Item 4. Information
 on the Company - B. Business Overview

 We have provided additional disclosure for the full scope and business
plan of our AI services.

 · Historical results
 of the Predecessor and the Successor and tabular presentations

 We have revised our discussion of operating
results throughout this annual report to separately present and discuss the historical results of the Predecessor and the Successor.
In addition, we have revised the tabular presentations to present data consistently from left to right in the same chronological order
throughout this annual report.

 · Notes to Consolidated
 Financial Statements – 1. Organization and Principal Activities

 We have revised the description regarding our acquisition of the
Predecessor.

 Except as set forth herein, the Company has
not modified, or updated any other disclosures and has made no change to the 2024 Form 20-F. Other than as expressly set forth above,
this Amendment No. 1 does not, and does not purport to, amend, update or restate the information in any part of the 2024 Form 20-F or
reflect any events that have occurred after the 2024 Form 20-F was filed on January 27, 2025. The filing of this Amendment No. 1, and
the inclusion of newly executed certifications, should not be understood to mean that any other statements contained in the original
filing are true and complete as of any date subsequent to January 27, 2025. Accordingly, this Amendment No. 1 should be read in conjunction
with the 2024 Form 20-F and the documents filed with or furnished to the SEC by the Company subsequent to January 27, 2025, including
any amendments to such documents.

 TABLE OF CONTENTS

 INTRODUCTION
 ii

 PART I
 1

 ITEM 1.
 IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS
 1

 ITEM 2.
 OFFER STATISTICS AND EXPECTED TIMETABLE
 1

 ITEM 3.