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CORRESP
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Magnitude
International Ltd

March
3, 2026

Via Edgar

Division
of Corporation Finance

Office of Real Estate & Construction

U.S.
Securities and Exchange Commission

100
F Street, NE

Washington, D.C., 20549

    Attention:

    Jeffrey
    Lewis

    Jennifer
    Monick

    Re:

    Magnitude
    International Ltd

    Form
    20-F for the fiscal year ended April 30, 2025

    File No. 001-42770

Ladies
and Gentlemen:

On
behalf of Magnitude International Ltd (the “Company”), we submit to the staff (the “Staff”) of
the U.S. Securities and Exchange Commission (the “Commission”) this letter setting forth the Company’s response
to the comments contained in the Staff’s letter dated February 23, 2026 on the Company’s Form 20-F for the fiscal year ended
April 30, 2025 submitted on September 15, 2025. Concurrently with the submission of this letter, the Company is submitting its Amendment
No.1 to the Form 20-F for the fiscal year ended April 30, 2025 (the “Revised Form 20-F”) and certain exhibits via
EDGAR to the Commission.

The
Staff’s comments from its letter dated February 23, 2026 are repeated below in bold and followed by the Company’s responses.
We have included page numbers to refer to the location in the Revised Form 20-F where the language addressing the comments appears. Capitalized
terms used but not otherwise defined herein have the meanings set forth in the Revised Form 20-F.

Form
20-F for the fiscal year ended April 30, 2025 Item 15.

Controls and Procedures, page 76

1. Please
                                            amend your filing to disclose the conclusions of your principal executive and principal financial
                                            officers, or persons performing similar functions, regarding the effectiveness of your disclosure
                                            controls and procedures as of April 30, 2025. Please refer to Item 15(a) of Form 20-F.

The
Company respectfully acknowledges the Staff’s comment and has added the relevant disclosure on page 76 of the Revised Form 20-F.

Item
16K. Cybersecurity, page 78

2. Please
                                            tell us why cybersecurity disclosure is not applicable given that Item 16K applies to annual
                                            reports on Form 20-F, or amend your filing to include the applicable cybersecurity disclosures.
                                            See Instruction to Item 16K of Form 20-F.

The
Company respectfully acknowledges the Staff’s comment and has revised the referenced disclosure on page 78 of the Revised Form
20-F.

Exhibits

 3. We
                                            note the certifications required by Rules 13a-14 and 15d-14 of the Exchange Act have been
                                            omitted from your Form 20-F. Please file an amended Form 20-F in its entirety and include
                                            the certifications from your principal executive officer and principal financial officer,
                                            or persons performing similar functions, as exhibits in accordance with the general instructions
                                            and instructions as to exhibits of Form 20-F.

The
Company respectfully acknowledges the Staff’s comment and has revised the list of exhibits under Item 19. Exhibits of the Revised
Form 20-F to reflect the filing of the certificate of principal executive officer and principal financial officer pursuant to Section
302 and Section 906 of the Sarbanes-Oxley Act of 2002, as required under Rules 13a-14 and 15d-14 of the Exchange Act.

Yours
sincerely,

For and on behalf of

Magnitude
International Ltd

  Lim
Say Wei

  Director & CEO