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CORRESP
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Transit
Pro Tech Inc.

100
N. Barranca, Street, Suite 460

Covina,
California 91791

July
29, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Technology

Washington,
D.C. 20549

Attn:  Marion
Graham

 Re: Transit
Pro Tech Inc.

Registration
Statement on Form 10-12G

Filed
July 1, 2024

File No. 000-56650

Ladies
and Gentlemen:

Concurrently
with this letter Transit Pro Tech Inc. (the “Company”) is filing Amendment No. 1 to the above-referenced Registration
Statement on Form 10-12G (“Amendment 1”). To assist the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) in its review of Amendment 1, the Company is providing the information below
in response to the comment letter received from the Staff dated July 19, 2024.

For
the Staff’s convenience, we have repeated below the Staff’s comments in bold and have followed each comment with the
Company’s response. Disclosure changes made in response to the Staff’s comments have been made in Amendment 1 which
is being submitted contemporaneously with the submission of this letter.

Registration
Statement on Form 10-12G

Item
1. Business

Sales
and Marketing, page 5

 1. We
note your disclosure that "[M]uch of our intellectual property, including patents filed in the United States, will be owned
by TP Hong Kong" rather than being owned by Transit Pro Delaware. Please revise to provide a more complete discussion regarding
the risks associated with your Hong Kong subsidiary owning your intellectual property.

Disclosure
has been added under the subheading Sales and Marketing in Item 1 alerting the reader to the risks associated with the ownership
of the Company’s intellectual property. Additional disclosure with respect to this issue has also been included in the first
Risk Factor under the subheading “Risks Associated with Business Operations in China” and the subsequent Risk Factor
now titled “China is a communist country. As such, the Chinese central government and local governments, including the government
in Hong Kong, may take actions believed to be beneficial to the common good at the expense of an individual business.”

Item
4. Security Ownership of Certain Beneficial Owners and Management, page 40

 2. We
                                         note your references to the irrevocable proxy granted to Mr. Du to vote or otherwise
                                         act with respect to all outstanding Class B Common Stock. Given those voting agreements,
                                         please add a column to the beneficial ownership table to reflect the aggregate voting
                                         power granted to Mr. Du that includes the combined voting power with the irrevocable
                                         proxies.

The
requested columns have been added.

General

 3. We
                                         note your disclosure that you will transfer any dividends to TP Hong Kong in accordance
                                         with the laws and regulations of the PRC, and then TP Hong Kong will transfer the dividends
                                         to Transit Pro Delaware. Please revise as appropriate to clarify that the risks applicable
                                         to PRC companies are also applicable to your Hong Kong subsidiary, specifically as it
                                         relates to the transfer of cash and issuance of dividends.

Disclosure
has been added on page 12 at the end of the subsection “Foreign Currency Exchange” with respect to the risks associated
with exchanging currencies in Hong Kong for the purpose of making payments outside of the PRC and Hong Kong. In addition, language
has been added to the Risk Factors now titled “The transfer of funds between Transit Pro Delaware and our subsidiaries in
China and Hong Kong is subject to restriction. The transfer of funds by Beyebe to Beyebe AI for purposes of making a loan to us
is subject to restriction” and “Under laws and regulations in China and Hong Kong, our subsidiaries in the PRC and
Hong Kong are limited in their ability to pay dividends to us, which may impair our ability to pay dividends and to fund our United
States segment in the future.”

We
remind you 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.

The
Company appreciates the comments received from the Staff as a result of its review and understands that it and its management
are responsible for the accuracy and adequacy of the disclosures in its filings.

We
thank the Staff for its review of this response. Should you have any questions or require any additional information, please do
not hesitate to contact our legal counsel, Vincent McGill Ellenoff Grossman & Schole LLP, at vmcgill@egsllp.com or by telephone
at (516) 220-6569.

    Very truly yours,

    Transit Pro Tech Inc.

    By:
    /s/
    Weihong Du

    Name:
     Weihong
    Du

    Title:
    Chief Executive Officer

cc:
Ellenoff Grossman & Schole LLP