SecProbe.io

September 30, 2024
Ngo Chiu Lam
Chief Executive Officer
Skyline Builders Group Holding Limited
Office A, 15/F, Tower A, Capital Tower
No. 38 Wai Yip Street
Kowloon Bay
Hong Kong
Re:Skyline Builders Group Holding Limited
Amended Draft Registration Statement on Form F-1
Submitted September 16 and September 23, 2024
CIK No. 0002031009
Dear Ngo Chiu Lam:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on EDGAR.
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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
September 5, 2024 letter.
Amended Draft Registration Statement on Form F-1
Management's Discussion and Analysis...
Liquidity and Capital Resources, page 61
1.We note your revised disclosure in this section in response to prior comment 4; however,
the maturity dates for much of your debt as disclosed including in the table starting on
page 61 and in your disclosure on page 63 appear to have passed. We note, for example,
your disclosure that you re-drew from your revolving loan facilities, resulting in an
outstanding balance of US$6,358,678 as of July 31, 2024. Please revise your disclosure
throughout this section to clarify the current status of your indebtedness.

September 30, 2024
Page 2
Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-13
2.We note your response to prior comment 7. Please further expand your disclosures to
state when you expect to recognize revenues related to unsatisfied (or partially
unsatisfied) performance obligations. Refer to ASC 606-10-50-13(b).
17. Segment Reporting, page F-33
3.We note your response to prior comment 12 that the Company operates in a single
segment that represents its core business as an Approved Public Works Contractor
involving integrated services such as site formation, reinforced concrete works, and
drainage, which are components of comprehensive contracts rather than distinct products
or services. Please further clarify for us whether the Company is providing only road and
drainage work in its contracts whereby the construction activities you disclose as
undertaken by the Company on page 76 such as site formation works, reinforced concrete
structure works, road and drainage works, earthworks and landscape works are integrated
into the final deliverable or whether the Company also engages specifically in providing
contracts related to site formation, drainage and reinforced concrete projects separately as
the final deliverable. In that regard, we note the disclosure on page 73 related to the
overview of civil engineering works in Hong Kong which seems to view road and
drainage work and site formation as separate segments in the civil engineering
works industry. It also appears there are sub categories such as construction and
maintenance for some of these categories. We remind you that the disclosure
requirements in ASC 280-10-50-40 are required even if a Company operates in a single
reportable segment.
            Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at 202-551-3269 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Lawrence S. Venick, Esq.