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      SSHT S&T Group Ltd.

      46 Reeves Road, Pakuranga

      Aukland, New Zealand, 2010

      October 26, 2023

      Attorney Robert Shapiro

      Division of Corporation Finance

      Securities and Exchange Commission

 Re: SSHT S&T Group Ltd.

    Amendment No. 3 to Registration Statement on
                                            Form S-1

    Filed September 8, 2023

    File No. 333-271831

      Dear Mr. Shapiro:

      In response to your letter dated October 4, 2023, the following information is hereby submitted on behalf of SSHT S&T Group Ltd (the "Company"). Amendment No. 4 to the Registration Statement on Form S-1 is being filed in conjunction with this correspondence. We have reproduced the Staff’s comments below in italicized text immediately before our response.

      Amendment No. 3 to Registration Statement
on Form S-1 filed September 8, 2023

      Cover Page

            1.
            We note your response to comments 2 and 10 and the reference on the prospectus cover
               page to the risk factor on page 12 that “[t]here are significant uncertainties under
               the Draft Foreign Investment Law relating to the status of businesses in China controlled
               by foreign invested entities primarily through contractual arrangements, such as our
               business.” As you have represented and now disclose that you do not rely on contracts
               to control your business and instead rely on direct ownership, please update these
               references accordingly.

      Response: We have updated the Registration Statement as requested.

            2.
            Please add a new risk factor related to your disclosure that the "Company has not
               sought to engage PRC counsel to obtain an additional opinion pertaining to the Company’s understanding of all required approvals and permission to operate [its] business.".

      Response: We have removed such disclosure as we have engaged Chinese legal counsel. As such, we do not believe the requested risk factor should be included at this time.

            3.
            We note your response to comment 6 and your cross reference to your discussion about
               how cash is transferred in your summary and risk factors section. Please revise to
               include a cross reference to your summary risk factors section.

      Response: We have updated the Registration Statement as requested.

            4.
            We note your response to comment 9. We note there remain references on the cover page
               to the term "Material PRC Company." Please define the entity to which you are referring.

      Response: We have updated the Registration Statement to remove references to the term “Material PRC Company.”

      Prospectus Summary, page 1

            5.
            We note your response to comment 13. Please revise to include your disclosure about
               permissions and approval requirements, as you do under the "Regulatory Permission"
               on the cover page. In addition, revise to include references to your subsidiaries
               in this discussion. In this regard, we note your disclosure that "we are not currently
               required to obtain approval from Chinese authorities," and that on page 1 you state
               that "references in this prospectus to “the Company,” “SSHT,” “we,” “our,” “us” refer
               to SSHT S&T Group Ltd."

      Response: We have updated the Registration Statement as requested.

      Summary of Risk Factors, page 8

            6.
            We note your response to comment 11 and reissue in part. Please revise to include
               a summary of the risk and uncertainties regarding the enforcement of laws. Additionally,
               please revise your second bulleted summary of risk factor under Risks Related to Doing
               Business in China to include that the Chinese government may intervene or influence
               your operations at any time, or may exert more control over offerings conducted overseas
               and/or foreign investment in China-based issuers, which could result in a material
               change in your operations and/or the value of the securities you are registering for
               sale.

      Response: We have updated the Registration Statement as requested.

      Risks Related to Doing Business in China

      We face uncertainties with respect to indirect transfers of equity interests in PRC
         resident..., page 13.

            7.
            We note your response to comment 18 and reissue in part for clarification about the
               indirect transfers of equity interests by non-PRC holding companies. Describe such
               transfers and how they are regulated, as well as how such transfers could result in
               a material change in your operations or the value of your common shares.

      Response: We have updated the Registration Statement as requested.

      To the extent any funds or assets in the business are in mainland China or a mainland
         China entity…, page 18.

            8.
            We note your response to comment 7 and your cross reference to this risk factor on
               the cover page. Please revise to amend this risk factor to state that "to the extent
               cash in the business is in the PRC/Hong Kong or a PRC/Hong Kong entity, the funds
               may not be available to fund operations or for other use outside of the PRC/Hong Kong
               due to interventions in or the imposition of restrictions and limitations on the ability
               of you or your subsidiaries by the PRC government to transfer cash. In this regard,
               we note that your disclosure does not reference Hong Kong and references "assets (other
               than cash)."

      Response: We have updated the Registration Statement as requested.

      Management’s Discussion and Analysis of Financial Condition and Results of Operations Going Concern,
         page 34

            9.
            We note your revised disclosure in response to comment 25. Please update your discussion to present the accumulated deficit at June 30, 2023 and the net loss for the six months ended June 30, 2023 consistent with your interim financial statements for the six months ended June 30, 2023.

      Response: We have updated the Registration Statement as follows (see page 32):

      Off-Balance Sheet Arrangements

      As of June 30, 2023, we do not have any off-balance sheet arrangements that have or are reasonably
         likely to have a current or future effect on our financial condition, changes in financial
         condition, revenues or expenses, results of operations, liquidity, capital expenditures
         or capital resources that are material to investors.

      Going Concern

      The accompanying consolidated financial statements have been prepared on a going concern
         basis, which contemplates the realization of assets and the satisfaction of liabilities
         in the normal course of business. The Company had an accumulated deficit of $(2,582,490) on June 30, 2023, with an accumulated deficit of $(2,533,986) at December 31, 2022. The Company had net loss attributable to the Company of $48,504 for the six months ended June 30, 2023, and net loss attributable to the Company of $77,804 for the six months ended June 30, 2022. The Company’s ability to continue as a going concern is dependent upon its ability to generate
         positive cash flow from an operating company, and/or raise capital through equity
         and debt financing or other means on desirable terms. If the Company is unable to
         obtain additional funds when they are required or if the funds cannot be obtained
         on favorable terms, management may be required to restructure the Company or cease
         operations. The consolidated financial statements do not include any adjustments that
         might result from the outcome of these uncertainties.

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      Note 7. Related Parties

      Balances with Related Parties, page F-16

            10.
            Your disclosure in Note 7 indicates that during the years ended December 31, 2022, and 2021, Mr. Zonghan Wu advanced a total of $81,823 and $115,939 to the Company for payment of administrative fees and legal expenses. Based on your disclosures in the
               cash flow statements for these periods, it appears that these amounts represent the amounts
               still outstanding at December 31, 2022, and 2021 rather than the amounts advanced or paid to or on behalf of the Company during the period. Please advise or revise as appropriate. Also, please explain why the advances due to a related party, Mr. Zonghan Wu, were reduced by the fair value of the 55,800,000 common shares issued to Zhibin Chen of $55,800 as your current disclosures in your cash flow statement and Note 7 appear
               to indicate. In addition, your cash flow statement and statement of changes of equity
               for 2022 indicate that these shares were issued for services and a reduction of related
               party debt while the disclosure in Note 7 indicate that these shares were issued for consulting service fees. Please clarify the number of shares and related fair value of the shares
               issued for a reduction of debt as well as those issued for services and reconcile and revise
               the disclosures in your cash flow statement and statement of changes in shareholder’s equity with those in Note 7 to the audited financial statements.

      Response: We have updated the Registration Statement as follows:

      We have updated Note 7.

      We have updated the cash flow statement and statement of changes in equity for 2022. On February 11, 2022, Zhibin Chen, the former director of the Company, was awarded 55,800,000 common
         shares for consulting service fees. The amounts of changes in related party transactions
         are as follows.

    Item

    12/31/2021
    Debit
    Credit
    12//31/2022

    US$
    US$
    US$
    US$

    Amounts due to a related party-Zonghan Wu
    115,939
    251,123
    217,007
    81,823

    Amounts due to a related party-Zhibin Chen
    -
    55,800
    55,800
    -

    Total
    115,939
    306,923
    272,807
    81,823

      General

            11.
            We reissue comment 40. Please revise to add a Description of Business section, pursuant to Item 101 of Regulation S-K.

      Response: We have updated the Registration Statement as requested.

      We are aware that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
         absence of action by the staff. Please let me know if you need anything further.

  Sincerely,

  SSHT S&T Group Ltd

  /s/ Zonghan Wu

  CEO and Director

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