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CORRESP
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December 30, 2024

VIA EDGAR

Claire DeLabar

Robert Littlepage

Uwem Bassey

Jeff Kauten

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Nidar Infrastructure Limited

    Registration Statement on Form F-4

    Filed November 13, 2024

    File No. 333-283189

Dear Ms. DeLabar:

This letter is in response
to the comments of the staff of the United States Securities and Exchange Commission (the “Staff”) contained in your
letter dated December 11, 2024 (the “Comment Letter”), regarding the Registration Statement on Form F-4 (the
 “Registration Statement”), which was filed by Nidar Infrastructure Limited (the “Company” or “Nidar”)
with the United States Securities and Exchange Commission (the “Commission”) on November 13, 2024.

The Company has filed today
Amendment No. 1 to the Registration Statement (“Amendment No. 1”) together with this letter via EDGAR correspondence.
For the convenience of the Staff, the numbering of the paragraphs below corresponds to the numbering of the comment in the Comment Letter,
the text of which the Company has incorporated into this response letter in italicized type, and which is followed by the Company’s
response. Unless otherwise indicated, all page references in the responses are to page numbers in Amendment No. 1. Capitalized
terms used herein but not defined shall have the meanings ascribed to them in Amendment No. 1.

Cover Page

 1. Comment: Please disclose here and in the summary section that Nidar is contemplating issuing
additional securities in a private placement to PIPE Investors. Also disclose any material financing transactions that have occurred since
the initial public offering of the special purpose acquisition company or will occur in connection with the consummation of the de-SPAC
transaction. Refer to Items 1604(a)(2) and 1604(b)(5) of Regulation S-K.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on the cover page of Amendment No. 1 to disclose
that Nidar is contemplating issuing additional securities in a private placement to PIPE Investors and to disclose the material financing
transactions that Cartica Acquisition Corp (“Cartica”) has consummated since its initial public offering. Cartica does
not currently intend to consummate any additional material financing transactions in connection with the consummation of the de-SPAC transaction,
but the Company undertakes to update the disclosure on the cover page of any future amendments to the Registration Statement to discuss
any additional material financing transactions of Cartica that are consummated or are in the future expected to be consummated in connection
with the consummation of the de-SPAC transaction.

Prospectus Summary

Redemption Rights, page 42

 2. Comment: Please clarify that shareholders may exercise their redemption rights regardless of
how they vote with respect to the proposed business combination.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 42 of Amendment No. 1 to clarify that
shareholders may exercise their redemption rights regardless of how they vote with respect to the proposed business combination.

The Cartica Board’s Reasons for the Business
Combination, page 44

 3. Comment: Please disclose the source of your statement that “IT MW supply in India is anticipated
to grow at an annual compounded growth rate of 17% versus 12% in the U.S. over the same period.”

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 46 and 182 of Amendment No. 1 to
describe the source of this information.

Compensation Received by the Sponsor, page 49

 4. Comment: Please include disclosure outside of the table regarding the extent to which the compensation
and securities issuances described in the table have resulted or may result in a material dilution of the equity interests of non-redeeming
shareholders of the special purpose acquisition company. Refer to Item 1604(b)(4) of Regulation S-K.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 51 of Amendment No. 1 to include disclosure
outside of the table regarding the extent to which the securities issuances described in the table have resulted or may result in a material
dilution of the equity interests of non-redeeming shareholders of Cartica. The Company respectfully advises the Staff that the payments
pursuant to the Administrative Support Agreement, dated January 4, 2022, by and between Cartica and Cartica Acquisition Partners,
LLC (the “Sponsor”), as amended, do not have a materially dilutive effect on the equity interests of non-redeeming shareholders,
and the Company does not feel that additional disclosure would materially improve an investor’s understanding of the benefits of
the transaction to the Sponsor. Further, the Company respectfully advises the Staff that the repayment of the notes issued to the Sponsor
will not have an effect on the net assets of the surviving company as such payments constitute a reduction of an asset (cash) and a reduction
of a liability (Promissory note – related party), and, therefore, the repayment of the notes issued to the Sponsor will not result
in material dilution of the equity interests of non-redeeming shareholders of Cartica.

Unaudited Pro Forma Condensed Combined Financial
Statements

Note 4 - IFRS Conversion and Presentation Alignment,
page 76

 5. Comment: Please expand the disclosure to explain the reason for classifying the Cartica Class A
ordinary shares subject to redemption as a non-current financial liability under IFRS 2 rather than as a current liability.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 76 of Amendment No. 1 to explain the
reason for classifying the Cartica Class A ordinary shares subject to redemption as a non-current financial liability under IFRS
2 rather than as a current liability.

Risk Factors

Nidar has substantial debt and faces risks
associated with the use of debt..., page 89

 6. Comment: Please quantify your debt service requirements and disclose the percentage of your
cash flow that must be dedicated to debt service, both principle and interest.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 89 and 90 of Amendment No. 1 to quantify
Nidar’s debt service requirements and disclose that its cash flow may not be sufficient to cover its debt.

We depend on significant customers..., page 93

 7. Comment: We note your disclosure that your top three customers represented 50% of your total
annualized recurring revenue generated by your properties as of March 31, 2024. Please revise to identify these customers and disclose
the material terms of your agreements with these customers including the term and any material termination provisions.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 93 and 94 of Amendment No. 1 to describe
the top three customers and disclose the material terms of Nidar’s agreements with these customers including the term and any material
termination provisions.

Other General Risks Related to Cartica, page 103

 8. Comment: Please add a risk factor that Cartica’s securities will be suspended from trading
on Nasdaq and delisted if the business combination is not consummated by January 4, 2025.

Response:
The Company acknowledges the Staff’s comment and has added a responsive risk factor under the caption “If Cartica fails
to complete a business combination within 36 months of the IPO, the Cartica Class A Shares, Cartica Units and Cartica Public Warrants
will be delisted from the Nasdaq Capital Market. This may result in Cartica Class A Shares, Cartica Units and Cartica Public Warrants
to be traded over the counter, which could have a material adverse effect on the market prices of Cartica’s securities and on shareholder
liquidity” on pages 108 and 109 of Amendment No. 1.

Risks Related to the Business Combination

J.P. Morgan Securities LLC, the underwriter
for the IPO..., page 118

 9. Comment: Please revise to disclose that investors should not place any reliance on the fact
that J.P. Morgan has been previously involved with Cartica and discuss the material impact, if any, of agreement provisions that survive
the termination of its association with Cartica, such as indemnification, contribution, rights of first refusal or lockups.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 121 of Amendment No. 1 to disclose
that investors should not place any reliance on the fact that J.P. Morgan has been previously involved with Cartica and discuss the impact
of provisions that survive the termination of its association with Cartica.

Nidar is expected to be a “controlled
company” within the meaning of the applicable rules of Nasdaq..., page 128

 10. Comment: Please quantify the percentage of voting power that will be held by Vista Holdings
Limited upon the closing of the business combination based upon the No Redemption Scenario and the Maximum Redemption Scenario.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 131 of Amendment No. 1 to quantify
the percentage of voting power that will be held by Vista Holdings Limited upon the closing of the business combination based upon the
No Redemption Scenario and the Maximum Redemption Scenario.

The Business Combination Agreement and Ancillary
Documents

The Cartica Board’s Reasons for the Business
Combination, page 177

 11. Comment: Please revise to include a discussion of dilution as one of the material factors considered
by Cartica’s board of directors in determining whether the de-SPAC transaction is advisable and in the best interests of the special
purpose acquisition company and its security holders or advise. Refer to Item 1606(b) of Regulation S-K.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure under the former caption “Minority position,”
which is now captioned “Cartica’s Public Shareholders Will Have a Minority Ownership Interest in Nidar,” on pages 49
and 185 of Amendment No. 1 to include a more detailed discussion of dilution as one of the material factors considered by Cartica’s
board of directors in determining whether the de-SPAC transaction is advisable and in the best interests of the special purpose acquisition
company and its security holders.

Information Related to Cartica

Directors and Executive Officers, page 196

 12. Comment: Please revise to disclose the experience of the SPAC sponsor, its affiliates, and any
promoters in organizing special purpose acquisition companies and the extent to which the SPAC sponsor, its affiliates, and the promoters
are involved in other special purpose acquisition companies. Refer to Item 1603(a)(3) of Regulation S-K.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 206 of Amendment No. 1 to disclose
the experience of the SPAC sponsor and its affiliates in organizing special purpose acquisition companies and the extent to which the
SPAC sponsor and its affiliates are involved in other special purpose acquisition companies. The Company respectfully advises the Staff
that the Company is not aware of any experience or involvement of Cartica’s promoters with any other special purpose acquisition
companies.

Information about Nidar

Overview, page 207

 13. Comment: We note your disclosures that Nidar provides AI services. Please provide a materially
complete discussion of what you mean by AI services and also clarify and whether you utilize third-party artificial intelligence products.

Response:
The Company acknowledges the Staff’s comment and has revised the disclosure on page 217 of Amendment No. 1 to provide
a materially complete discussion of what Nidar means by AI services and to clarify and whether Nidar utilizes third-party artificial intelligence
products.

Certain Relationships and Related Person Transactions

Nidar Related Person Transactions, page 251

 14. Comment: Please file the material related party agreements in this section as exhibits to your
registration statement. Refer to Item 601(b)(10)(ii)(A) of Regulation S-K.

Response:
The Company acknowledges the Staff’s comment. The Company has included material related party agreements as Exhibits 10.21 through
10.27 in the registration statement (the “filed related party agreements”) described in the chart below. The filed related
party agreements represent all of the material related party agreements to which Nidar is a party and which will remain in force following
January 1, 2025. The other related party transactions arise primarily on an ad hoc basis, and are typically not entered into in connection
with a pre-existing written agreement. There are numerous Unsecured Perpetual Debt documents from the related party in favor of a number
of Nidar subsidiaries. The filed documents are representative of all of the Unsecured Perpetual Debt documents.

    Related Party
    Nature of Contract

    Niranjan Hiranandani
    Unsecured Perpetual Debt

    Kamal Hiranandani
    Unsecured Perpetual Debt

    Persipina Developers Private Limited
    NM1 Lease

    Volupia Developers Private Limited
    G1 Lease

    Volupia Developers Private Limited
    G1 Lease

    Persipina Developers PVT. Ltd.
    NM2 Lease

    Darshan Hiranandani
    Trademark License Agreement

Financial Statements - Nidar Infrastructure
Limited

Note 3.7. Property, Plant and Equipment, page F-20

 15. Comment: We note that during the period, you reassessed the useful lives of certain assets from
3 years to 8 years. Please expand the disclosure to include the date of the change, the category of assets impacted, and the amount of
the impact prospectively in fiscal 2024 or estimated for fiscal 2025.

Response:
The Company acknowledges the Staff’s comment. The change in the determination of useful lives material should not have been included
in the financial statements, since it did not occur until after the financial statements had been prepared for the year ending March 31,
2024. Reference to the change in useful lives has been removed on page F-21 of Amendment No. 1.

Note 13. Goodwill, page F-38

 16. Comment: We note in your disclosure of subsidiaries on page F-64 that NUI Services is a
Utility, NIDP Developers is a Data Center and Globus Data is an Investing entity. Please expand the disclosure to describe the nature
of the cash generating units by type of asset.

Response:
The Company acknowledges the Staff’s comment. Under Note 13, we have disclosed the respective CGUs to which goodwill has been allocated.
In our case, the respective legal entities are identified as CGUs, and their names have been disclosed in Note 13. Furthermore, the principal
business activity of each legal entity has been disclosed under Note 37. As the total assets of the legal entity are included within the
CGU, we believe that a separate disclosure describing the type of assets within the CGU is not required, as the existing disclosures provide
sufficient information to meet the requirements of IAS 36.

Note 17. Cash and cash equivalents, page F-40

 17. Comment: Refer to Risk Factors on page 91 that states that Nidar is subject to legal restrictions
on the convertibility of currencies in India, which could limit Nidar’s ability to use cash generated in India in another country.
Please expand the disclosure to quantify the amount of cash and cash equivalents subject to restrictions.

Response:
The Company acknowledges the Staff’s comment. The amount of cash and cash equivalents disclosed in the financial statements is not
subject to legal restrictions on currency convertibility. However, if the Company decid