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CORRESP
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SCHLUETER
& ASSOCIATES, P.C.

5655
SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD
VILLAGE, CO 80111

TELEPHONE:
+1-303-292-3883

FACSIMILE:
+1-303-648-5663

Email:
hfs@schlueterintl.com

May
8, 2024

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Rucha Pandit

    Re:

    Premium
                                            Catering (Holdings) Ltd

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

    Submitted
    March 21, 2024

    CIK
    No. 0001998056

Dear
Ms. Pandit,

Please
accept this letter as the response of Premium Catering (Holdings) Ltd (“Registrant” or “Company”)
to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
with respect to Amendment No. 1 of the Draft Registration Statement on Form F-1 confidentially submitted to the Commission on March 21,
2024 (the “Registration Statement”). The Company is concurrently filing a registration statement on Form F-1 with
the Commission (the “Revised Registration Statement”), which includes amendments in response to the Staff’s
comments on the Registration Statement.

For
your convenience, the comments have been reproduced below, followed by the Registrant’s response.

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

Risk
Factors

As
a “controlled company,” we are exempt from certain Nasdaq corporate governance

requirements
. . ., page 24

 1. Please
                                            further revise this risk factor to identify the controlling shareholders and disclose that
                                            the controlling shareholders will have the ability to determine all matters requiring approval
                                            by stockholders, as you do in the section captioned “Implications of Being a ‘Controlled
                                            Company’” on page 15. Additionally, we note your representation here that you
                                            are a controlled company because “one of [y]our shareholders holds more than 50% of
                                            our voting power.”

However,
your disclosure on page 15 indicates that there are two controlling shareholders. Please advise or revise here and elsewhere as appropriate
to address this discrepancy.

Response:

The
Registrant has revised the Revised Registration Statement throughout to reflect that there is only one controlling shareholder, Hero
Global.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

Exposure
to risks associated with food safety and the food supply chain may subject us to

liability
. . ., page 38

 2. We
                                            note your response to prior comment 6 and reissue it. The disclosure here states that you
                                            are “exposed to risks associated with . . . the food supply chain, which may subject
                                            us to liability claims, damage our reputation and/or affect our relationship with our customers.”
                                            To the extent your business has been materially affected by disruptions to the food supply
                                            chain, please state as much and include a risk factor discussing this risk and how your business
                                            has been affected. In this regard, we note that your response addresses food safety, but
                                            does not address any risks associated with the food supply chain.

Response:

The
Registrant has removed this reference to a risk associated with the food supply chain.

Management

Employment
Agreements, page 96

 3. We
                                            note your response to prior comment 11. Please revise the Exhibit Index to comply with Item
                                            601(a)(2) of Regulation S-K. In this regard, we note that although Exhibit 10.2 is captioned
                                            as “Employment Agreement between Mr. Yu Chun Yin and Premium Catering,” it hyperlinks
                                            to the employment agreement with Ms. Zhang Xiao Ying. Relatedly, please file your employment
                                            agreement with Mr. Yu Chun Yin as an exhibit to the registration statement or tell us why
                                            you believe you are not required to do so. Refer to Item 601(b)(10)(ii) of Regulation S-K.

Response:

The
Registrant has included the Employment Agreement with Mr. Yu Chun Yin and Premium Catering as Exhibit 10.2 to the Revised Registration
Statement.

Notes
to Consolidated Financial Statements

Note
3 - Summary of Significant Accounting Policies

(l)
Revenue Recognition, page F-10

 4. We
                                            have reviewed your response to prior comment 15 noting your revenue is recorded net of goods
                                            and services tax. Please provided the disclosures required by ASC 606-10-32- 2A.

Response:

The
Registrant has included the disclosures required by ASC 606-10-32- 2A in the Revised Registration Statement on page F-10.

General

 5. On
                                            page Alt-4, please identify the natural person(s) with voting and/or investment control over
                                            the shares held by the entity selling shareholders.

Response:

The
Registrant has revised the Revised Registration Statement on page Alt-4 to reflect the persons who have voting and investment control
over the shares held by the entity selling shareholders.

The
Company respectfully requests the Staff’s assistance in completing its review of the Revised Registration Statement as soon as
possible. If you have any questions regarding the foregoing or desire further information or clarification, please do not hesitate to
contact the undersigned at (303) 868-3382.

Thank
you for your review.

    Very
    truly yours,

    /s/
    Henry F. Schlueter

    Henry
    F. Schlueter

    C:

    Premium
    Catering (Holdings) Ltd