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    Norton
    Rose Fulbright US LLP

    1301
    Sixth Avenue

    New
    York, NY 10019 United States

    Direct
    line +1 (212) 318-3168

    Rajiv.Khanna@nortonrosefulbright.com

    nortonrosefulbright.com

June
16, 2023

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street, N.E.

Washington,
D.C. 20549

Division
of Corporation Finance

Office
of Manufacturing

    Attention:
    Eranga
    Dias

Erin
Purnell

    Re:
    SRIVARU
    Holding Ltd

Amendment
No. 1 to

Draft
Registration Statement on Form F-4

Submitted
May 26, 2023

CIK
No. 0001973368

Dear
Mr. Dias and Ms. Purnell:

On
behalf of SRIVARU Holding Ltd (“SVH”, the “Registrant” or the “Company”), we are submitting via EDGAR
for review by the Securities and Exchange Commission (the “Commission”) this response letter and the accompanying Registration
Statement on Form F-4 (the “Registration Statement”). This letter and the Registration Statement reflect the Registrant’s
respectful acknowledgement and response to the comments received from the staff of the Commission (the “Staff”) contained
in the Staff’s letter dated June 9, 2023 (the “Comment Letter”) regarding Amendment No. 1 to the Registrant’s
Draft Registration Statement submitted May 26, 2023 (“Amendment No. 1”), and certain other updated information. Because several
of the items in the Comment Letter pertain to information regarding Mobiv Acquisition Corp (“MOBV”), we have included MOBV’s
responses in-line below. For your convenience, the Registrant is providing to the Staff a supplemental typeset copy of the Registration
Statement marked to indicate the changes from Amendment No. 1.

The
Staff’s comments as reflected in the Comment Letter are reproduced in italics in this letter, and the corresponding responses of
the Registrant are shown below each comment. All references to page numbers in the Registrant’s responses are to the page numbers
in the Registration Statement.

Amendment
No. 1 to DRS F-4 Submitted May 26, 2023

Notice
of Special Meeting of the Stockholders of MOBIV Acquisition Corp, page v

    1.
    Your
    disclosure indicates that the financial statements of SVM have been included in the filing. We note that the financial statements
    of only MOBIV and SVH have been included in the filing, and as such, please revise your disclosure accordingly or explain why you
    believe this disclosure is appropriate. This comment also applies to the reference to the consolidated financials of SVM in the Experts
    section on page 225.

Response:
SVH has updated the Registration Statement to correct these references and also to include updated financial statements of SVM as
predecessor entity pursuant to Comment 15 below.

Norton
Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.

Norton
Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright
South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose
Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each
entity, with certain regulatory information, are available at nortonrosefulbright.com.

Mr.
                                            Dias and Ms. Purnell

Securities
and Exchange Commission

June
16, 2023

Page
2

Redemption
Rights, page 27

    2.
    We
    reissue comment 10. We note that your revised disclosure cross-references an incorrect page number. Please revise to include the
    correct page number containing the tables that illustrate the potential impact of redemptions on the per share value of the shares
    owned by non-redeeming MOBV shareholders.

Response:
SVH has revised page 27 of the Registration Statement to include the correct page number containing the tables that illustrate
the potential impact of redemptions on the per share value of the shares owned by non-redeeming MOBV shareholders.

Organizational
Structure, page 101

    3.
    We
    note on pages 101-102 that you have multiple diagrams depicting ownership structures showing the ownership percentage of SVM held
    by “Current Minority SVM Shareholders” as 6%. We also note your disclosure in other parts of this registration statement
    that the ownership interest of the minority SVM shareholders is 3.98%. Please clarify or revise to correct.

Response:
The Company has revised disclosures in the Registration Statement on pages 107-108 to reflect the correct minority SVM shareholding
of 5.98%, which is rounded to 6% in the charts on pages 101-102.

On
March 11, 2023, the MOBV Board held a board meeting and agreed to increase the purchase price to be paid by MOBV to acquire SVH..., page
108

    4.
    We
                                            note your revised disclosure in response to comment 18 and reissue comment 18 in part. Please
                                            disclose:

    ●
    who
    was present at the board meeting held by the “MOBV Board” on March 11, 2023;

    ●
    how
    the value of the 3.98% share of SVM was determined to be $8,976,130;

    ●
    if
    the minority shareholders will retain ownership of their 3.98% share following the consummation of the business combination, whether
    there is a time limitation as to by when the minority shareholders must decide if they “wish to liquidate their holdings”
    in order to receive a predetermined value; and

    ●
    how
    the final value of the 3.98% share will be determined at the time of potential liquidation.

Response:
The Registration Statement has been revised on page 108 to reflect the MOBV Board members present and the subsequent information
requested above.

    5.
    We
                                            note your disclosure that “931,327 SVH Shares (accounted for as $8,976,130) would be
                                            held in reserve for the minority SVM shareholders until such time as they wish to liquidate
                                            their holdings.” We also note on p. 92 that these “951,327 SVH Shares will be
                                            authorized but unissued and reserved by SVH.” Please clarify who will receive the additional
                                            $8,976,130 or where it will be held, if 931,327 SVH shares will be authorized but
                                            unissued and reserved for the 3.98% share of SVM until a potential liquidation by the minority
                                            shareholders. Specifically, clarify whether SVH will receive the additional $8,976,130 in
                                            exchange for shares that are authorized and unissued, and also whether these shares shave
                                            been taken into consideration when calculating dilution.

Response:
SVH has revised the disclosure on page 92 of the Registration Statement to clarify that the 951,327 shares are to be used to liquidate
the SVM minority shareholders’ 5.98% position. Such shares have been taken into consideration when calculating dilution.

Norton
Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.

Norton Rose Fulbright US LLP, Norton Rose
Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate
legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate
the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory
information, are available at nortonrosefulbright.com.

Mr.
                                            Dias and Ms. Purnell

Securities
and Exchange Commission

June
16, 2023

Page
3

    6.
    We
    note your disclosure stating that “counter proposal by MOBV was that the total consideration would be for 100% of SVM (including
    the minority interest held by earlystage investors).” Please expand this disclosure to state whether the minority shareholders
    of SVM were part of this negotiation and include any material terms. Also disclose whether any agreements were entered into with
    the minority shareholders.

Response:
SVH has revised disclosures on page 108 to address the Staff’s comment.

Certain
Unaudited Projected Financial Information, page 113

    7.
    We
    note your revised disclosure in response to comment 30 and reissue in part. We also note your disclosure stating that the “projections
    are not in line with SVH’s historical operating trends or necessarily indicative of anticipated future sales in a market that
    is still in its formative stage, but merely to establish the basis for awarding the earn-out consideration to the SVH and SVM shareholders.”
    Given that your projections are not in line with your historic operating trends, please provide disclosure as to why the change in
    trends is appropriate or assumptions are reasonable. If the sole purpose for which projections were prepared was to establish the
    basis for awarding the earn-out considerations, with no materially adequate consideration as to whether their underlying change in
    trends is appropriate or assumptions are reasonable, explicitly disclose that throughout the registration statement where projections
    are present. In addition, provide explicit disclosure describing the risk that expectations of unusually high and/or sustained future
    growth may be unrealistic, given the assumptions as to future events, and may have resulted in inflated valuation conclusions.

Response: SVH
has provided information in Amendment No. 1 and the Registration Statement continues to include information on pages 114-115 which
describe the propriety of the changes in trends and the reasonability of assumptions. The fundamental premise of the projections is
that industry experts expect the E2W vehicle market to expand greatly over the next several years and SVH intends to capture a very
small fractional share of that growth. The fact that SVH is being assigned a much smaller valuation now, with the earn-out
valuations based on potential future growth serves to protect shareholders from possible inflated valuation conclusions because the
existing SVH shareholders will not receive the Earn Out Shares unless the earn-out metrics are achieved (or if the Board determines
appropriate when 50% of the metrics are achieved), while existing MOBV stockholders will benefit as SVH shareholders from even
limited growth that does not necessarily meet the earn-out metrics. The Company has further revised disclosures on pages 114-115
to address the Staff’s comment and comments below re projections.

The
projected financial information included in this registration statement was prepared by, and is the responsibility of, SVH’s management,
page 113

    8.
    We
    reissue comment 29. Please revise to provide detailed disclosures of the process undertaken to formulate the projections and assumptions,
    the parties who participated in the preparation of the projections, and how they were used.

Response:
As stated in Amendment No. 1 and the Registration Statement, SVH management members were the parties who participated in the preparation
of projections. SVH management has looked at third party market studies, competitors’ market share, its history of delivering product,
applications received from dealers, and indications of interest when its products were initially launched to formulate its projections.
SVH has used detailed statistical modeling to arrive at the expected numbers of production for each model in each year. The Company
has revised disclosures on pages 114-115 to address the Staff’s comment.

Projected
Pro Forma Vehicle Sales Revenue for SVH is based on assumptions related to..., page 114

    9.
    We
    reissue comment 26. Please revise your disclosure to provide greater specificity concerning each of the five material assumptions
    underlying your projections, specifically to quantify the assumptions, and to clearly explain how each of the five assumptions relate
    to the projected information.

Response:
The Company has revised disclosures on pages 114 to address the Staff’s comment.

In
preparing the Projections, SVH considered..., page 115

    10.
    We
    note your revised disclosure in response to comment 27 and reissue in part. Please revise to clearly identify the assumptions that
    underlie the projection and provide expanded disclosure that fully describe those assumptions as well as the type of market assumed
    in developing those assumptions.

Response:
The Company has revised disclosures on page 114-115 to address the Staff’s comment.

    11.
    We
    note your revised disclosure in response to comment 31 and reissue in part. We also note your disclosure stating that when deeming
    a guideline company to be reasonably comparable to SVH, “Marshall & Stevens also considered other relevant factors such
    as the Guideline Company’s operating history and, their strategy for future growth, their market share in the relevant markets
    that SVH operates, the Guideline Company’s size (market capitalization or enterprise value), and diversification in other business
    lines.” Please expand your disclosures as to each of the nine (9) reasonably comparable companies listed in the registration
    statement to describe how their data as to each of these relevant factors compare to SVH’s own, and your analysis based on
    the comparison that deemed each of the guideline companies to be reasonably comparable to SVH.

Response:
MOBV has revised the disclosure on page 116 of the Registration Statement to expand the disclosure regarding the nine comparable
companies and the rationale for their inclusion in the comparison to SVH.

Norton
Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.

Norton Rose Fulbright US LLP, Norton Rose
Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate
legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate
the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory
information, are available at nortonrosefulbright.com.

Mr.
                                            Dias and Ms. Purnell

Securities
and Exchange Commission

June
16, 2023

Page
4

SVH
Management’s Discussion and Analysis of Financial Condition and Results of Operation, page 177

    12.
    Please
                                            address the following regarding disclosures in this section of the document:

    ●
    You
    appear to use SVH and SVM interchangeably. Please revise your disclosures for consistency or explain why you believe your current
    disclosures are appropriate, and;

    ●
    The
    internal control disclosures on page 180 reference a year end of September 30, but SVH’s year end is March 31. Please revise
    as appropriate.

Response:
SVH has updated page 177 of the Registration Statement to correct the reference to SVM and page 180 to reference the March 31
year ends.

Quantitative
and Qualitative Disclosures About Market Risk, page 189

    13.
    Please
    revise your filing to accurately quantify your cash balance at the end of the most recently reported period, March 31, 2023, not
    December 31, 2023.

Response:
SVH has updated page 189 of the Registration Statement to quantify the cash balance at the end of March 31, 2023.

Mobiv
Acquisition Corp Au