SecProbe.io

November 4, 2024
Jervey Choon
Chief Executive Officer
TriUnity Business Services Ltd
BO1-A-09, Menara 2, KL Eco City, 3, Jalan Bangsar 59200
Kuala Lumpur, Malaysia
Re:TriUnity Business Services Ltd
Registration Statement on Form S-1
Filed October 8, 2024
File No. 333-282541
Dear Jervey Choon:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Please revise the registration statement cover page to disclose the name, address,
including zip code, and telephone number, including area code, of the company's
agent for service.  Please refer to Form S-1 cover page instructions.
2.The filing fee table and related disclosure required by Item 16.(c) of Form S-1 should
be included in a filing fee exhibit rather than on the registration statement cover page
of your filing. Please see Item 601(b)(107) of Regulation S-K.
3.Please revise the prospectus cover page to include the date of the prospectus.  Refer to
Item 501(b)(9) of Regulation S-K.  In this regard, we note that you have included such
date after the table of contents rather than on the prospectus cover page.

November 4, 2024
Page 2
Prospectus Summary, page 1
4.Please revise to acknowledge in your Prospectus Summary that you have identified
conditions and events that raise substantial doubt about your ability to continue as a
going concern and explain these conditions and events. Please also revise to provide a
risk factor discussing your ability to continue as a going concern. We note the
discussion of the substantial doubt as to your ability to continue as a going concern
reflected in the report of your independent registered public accountant.
Risk Factors, page 4
5.Include a risk factor alerting investors that as a company with a reporting obligation
under Section 15(d) of the Exchange Act, you will not be subject to the proxy rules,
Section 16 of the Exchange Act and certain of the tender offer rules. Please make
similar revisions to the disclosure under “Reports to Security Holders” on page 22,
and specify that you will file annual, quarterly and other required Exchange Act
reports.
6.Include a risk factor alerting investors that the company currently has one officer,
director and employee for all company business and operations.  Please also address
the large amount due to such officer and director.
Our principal executive offices are located in Malaysia and our Company has a non-U.S.
resident Officer and Director, page 5
7.We note that you disclose that there might be limits to the enforceability of civil
liability provisions of U.S. federal securities laws against the company’s officers and
directors, and company assets. Please more specifically revise your risk factor
discussion here to disclose an investor's ability:

•to effect service of process within the United States against any of your non-U.S.
resident officers or directors;

•to enforce U.S. court judgments based upon the civil liability provisions of the
U.S. federal securities laws against the company's officers and directors;

•to enforce in a Malaysian court a U.S. court judgments based on the civil liability
provisions of the U.S. federal securities laws against the above foreign persons;
and

•to bring an original action in a Malaysian court to enforce liabilities based upon
the U.S. federal securities laws against the above foreign persons.
We are an "emerging growth company" under the JOBS Act of 2012, page 6
8.Please revise your disclosure here and elsewhere as necessary to reflect the current
revenue threshold for remaining an emerging growth company (i.e., if your revenues
exceed $1.235 billion as compared to the $1 billion threshold currently disclosed).
Refer to Exchange Act Rule 12b-2.

November 4, 2024
Page 3
Management's Discussion and Analysis, page 14
9.Please remove the references to Section 27A of the Securities Act of 1933 and Section
21E of the Exchange Act of 1934. The statutory safe harbor for forward-looking
statements provided by these sections does not apply to statements made in
connection with an initial public offering.
10.We note your risk factor concerning inflation. Please clarify your MD&A discussion
as to the impact of inflation on your operations and results.
Global Human Resource Outsourcing Services Market Size, page 15
11.The reference to "billions" in the first paragraph appears incorrect based upon the
following chart.  Please revise as applicable.
Description of Business, page 16
12.Please note that the disclosure regarding the company's current business and
operations should accurately describe the current company rather than aspirational
business activities. Please revise to provide a more detailed summary of the
company's current business and operations to include the steps you have taken to date
to become an operating company. Please revise to clarify, if true, that the company
has provided limited accounting, bookkeeping, human resources and administrative
support services to date. To the extent that you discuss future business plans here,
such as the company's intentions to provide payroll management, document
management, expense management or training services, the discussions should be
balanced with a brief discussion on the time frame for implementing these future
plans, the steps involved, the associated costs, and any obstacles involved before the
company can commence the planned operations.  Lastly, to the extent the company
has not provided any services to date (i.e. payroll management or document
management), please revise to clarify that fact.
Marketing Strategy, page 17
13.We note your reference to your website. Please revise your disclosure to make clear
that your website, does not appear to be meaningfully functional. In this regard, please
disclose the timeline and costs for when the website will be functional.
Use of Proceeds, page 18
14.You state that as of July 31, 2024, your sole officer and director Ms. Jervey Choon
advanced the company a total of $28,949. Please clarify whether you intend to use a
portion of the net proceeds to repay the loans; and, where applicable, please revise to
discuss the material terms of the loan and file related agreements as exhibits to the
registration statement. Refer to Instruction 4 of Item 504 of Regulation S-K and Item
601(b)(10) of Regulation S-K.
Exhibits to Registration Statement, page 28
15.Please file as an exhibit a specimen stock certificate and any other instruments
defining the rights of shareholders. Refer to Item 601(b)(4) of Regulation S-K.

November 4, 2024
Page 4
Exhibits to Registration Statement
Consent of Independent Accounting Firm, page 28
16.The report date listed in your auditor consent does not agree with the report date of the
audit opinion included in your financial statements.  Please have your auditor revise
accordingly.
Report of Independent Registered Public Accounting Firm, page F-2
17.Please have your auditors revise their report to state, if true, the procedures and
opinion are for the period from April 30, 2024 (date of inception) to July 31, 2024
regarding all financial statements other than the balance sheet.
General
18.We note that this registration statement is substantially similar to registration
statements filed by Rocky Mountains Group Ltd. (i.e. a Form S-1; File No. 333-
281852) and Keemo Fashion Group Limited (i.e. a Form S-1; File No. 333-267967).
In this regard, we note that each of the filings uses a similar prospectus presentation
and formatting, offers a similar number of shares (i.e. 8,000,000) at the same offering
price of $0.015 per share, and contains similar risk factors, description of securities,
use of proceeds, plan of distribution, etc.  Additionally, we note that each company
retained the same auditor, i.e. JP Centurion & Partners PLT based out of Kuala
Lumpur, Malaysia.  Please advise regarding the substantially similar registration
statements.
19.We note that the attorney who has provided your legal opinion has disclaimed that he
prepared the registration statement. In this regard, Section 11 of the Securities Act of
1933 provides that any expert who helped prepare the registration statement, e.g.
accountants or lawyers, may be liable for any misrepresentation or omission of
material information in the registration statement. Please advise regarding the person,
attorney or service provider who prepared (or assisted in the preparation of) the
registration statement.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

November 4, 2024
Page 5
            Please contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services