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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

August
22, 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. 4 to Registration Statement on Form F-1

    Filed
    on August 5, 2024

    File
    No. 333-279843

    SEC
    Comment Letter dated August 22, 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. 5 (including certain exhibits) (“Amendment No. 5”) to the Registrant’s above-referenced Amendment No.
4 to Registration Statement on Form F-1 (the “Amendment No. 4”). This letter and Amendment No. 5 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 August 22, 2024 (the “Comment Letter”), comments received from the Staff via conference
call on August 19, 2022, and certain other updated information. For your convenience, the Registrant is providing to the Staff a supplemental
typeset copy of Amendment No. 5 marked to indicate the changes from the Amendment No. 4 that was filed on August 5, 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.

Mmes.
Jenny O’Shanick and Mrs. Erin Purnell

Securities
and Exchange Commission

August
22, 2024

Page
2

Amendment
No. 4 to Registration Statement on Form F-1

General

    1.
    Please
    confirm that each of the company and Maxim Group LLC did not use this Registration Statement on Form F-1 for the general solicitation
    of Ionic Ventures, LLC, the equity line investor named in the Registration Statement. Refer to Securities Act Release No. 8828 (Aug.
    3, 2007) and Securities Act Sections Compliance and Disclosure Interpretation 139.25.

Response:
Neither the Company nor Maxim Group LLC used the Company’s Registration Statement on Form F-1 (File No. 333-279843) or any amendment
thereto for the general solicitation of Ionic Ventures, LLC.

*    *    *

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. 5 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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