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    Norton Rose Fulbright US LLP

    1301 Avenue of the Americas

    New York, NY 10019-6022 United States

    Direct line +1 212-318-3168

    Rajiv.Khanna @nortonrosefulbright.com

    Tel +1 212 318 3000

    Fax +1 212 408 5100

    nortonrosefulbright.com

July
18, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

100
F Street, N.E.

Washington,
D.C. 20549

  Attention:
  Jenny O’Shanick

  Erin Purnell

    Re:
    SRIVARU Holding Limited

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

    Filed on June 25, 2024

    File No. 333-279843

    SEC Comment Letter dated July 3, 2024

Dear
Mmes. O’Shanick and Purnell:

On
behalf of SRIVARU Holding Limited (“SRIVARU”, 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
Amendment No. 2 (including certain exhibits) (“Amendment No. 2”) to the Registrant’s above-referenced Amendment No.
1 to Registration Statement on Form F-1 (the “Amendment No. 1”). This letter and Amendment No. 2 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 July 3, 2024 (the “Comment Letter”), and certain other updated information. For your convenience,
the Registrant is providing to the Staff a supplemental typeset copy of Amendment No. 2 marked to indicate the changes from the Amendment
No. 1 that was filed on June 25, 2024.

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 Amendment No. 2.

Mrs.
Jenny O’Shanick and Mrs. Erin Purnell

Securities
and Exchange Commission

July
18, 2024

Page
2

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

Executive
and Director Compensation, page 80

 1. We
                                            note your revisions in response to prior comment 2 and reissue in part. We note your disclosure
                                            that no compensation was paid “for the Company’s last full financial year since
                                            the period covered in this Registration Statement is the first applicable period for such
                                            disclosure since the closing of the Business Combination.” We also note that closing
                                            of the Business Combination occurred on December 8, 2023. Please revise to clarify whether
                                            the period in your revised disclosure covers the full financial year for the year ended March
                                            31, 2024. Further, we note your disclosure that initial grants of equity may have been granted
                                            to directors. Disclosure of compensation is required on an individual basis unless individual
                                            disclosure is not required in the company’s home country and is not otherwise publicly
                                            disclosed by the company. Please advise. Further, if the initial grants of equity were granted
                                            in the form of stock options, please provide the title and amount of securities covered by
                                            the options, the exercise price, the purchase price (if any), and the expiration date of
                                            the options. Finally, we note that the filing includes other footnotes that appear to be
                                            internal notes to update the disclosure as required. Please review and revise the footnotes
                                            on pages 5, 6, 49, 76, and 80 to ensure that your disclosure is complete and current.

Response:
We have revised the disclosure to clarify that the disclosure covers the full financial year through March 31, 2024, and that the home
country disclosure regime does not require compensation disclosure on an individual basis.

Index
to Financial Statements, page F-1

 2. Please
                                            update the financial statements and other financial information in the filing, including,
                                            but not limited to, MD&A, to comply with Item 8.A.4 of Form 20-F.

Response:
We have revised Amendment No. 2 to provide updated MD&A and audited financial statements for the year ended March 31, 2024.

*
    *     *

We
hope that the foregoing has been helpful to the Staff’s understanding of SRIVARU’s disclosure and that the disclosure modifications
in Amendment No. 2 are satisfactory to the Staff. If you have any questions or comments about this letter or need any further information,
please call the undersigned at (212) 318-3168.

    Very Truly Yours

    By:
    /s/
    Rajiv Khanna

    Rajiv
    Khanna

cc: Mohanraj
                                            Ramasamy (SRIVARU Holding Limited)

  Lee
McIntyre (Norton Rose Fulbright US LLP)

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