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CORRESP
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Magnitude
International Ltd

March
6, 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

    Amendment
    No. 1 to Form 20-F for the fiscal year ended April 30, 2025

    Response
    dated March 3, 2026

    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 March 4, 2026 on the Company’s Amendment No.1 to Form 20-F for the
fiscal year ended April 30, 2025 submitted on March 3, 2026.

The
Staff’s comments from its letter dated March 4, 2026 are repeated below in bold and followed by the Company’s responses.

Amendment
No. 1 to Form 20-F for the fiscal year ended April 30, 2025

Item
15. Controls and Procedures, page 76

    1.
    We
    note your response to our prior comment 1 and your amendment to your filing in response to our prior comments 1, 2, and 3 to include
    a conclusion regarding the effectiveness of your disclosure controls and procedures, include cybersecurity disclosures, and include
    the certifications from your principal executive officer and principal financial officer. In light of the amendment to address such
    previously omitted items, please tell us what consideration you gave to reconsidering your conclusion regarding your disclosure controls
    and procedures.

    The
                                            Company acknowledges the Staff’s comment. In response to the Staff’s comment,
                                            we respectfully advise the Staff of the following considerations made by management in connection
                                            with the filing of Amendment No. 1 to our Form 20-F for the fiscal year ended April 30, 2025.

    Upon
    identifying the need to amend our original Form 20-F to include the previously omitted items, management, including our principal
    executive officer and principal financial officer (the “Certifying Officers”), re-evaluated the effectiveness of our
    disclosure controls and procedures (“DCP”) as of April 30, 2025. This re-evaluation was conducted specifically to determine
    whether the omission of these items from the original filing indicated a material weakness or a significant deficiency in our DCP
    that would alter the original conclusion of effectiveness.

    The
    re-evaluation considered the following factors:

1. Nature
                                            of the Omissions: The omitted items—the explicit conclusion regarding DCP effectiveness,
                                            certain cybersecurity disclosures, and the signed certifications—were determined to
                                            be administrative and presentational omissions rather than substantive failures in the Company’s
                                            underlying information gathering and communication processes. The information supporting
                                            the DCP conclusion and the certifications existed and was known to management at the time
                                            of the original filing. The cybersecurity disclosures included in the amendment reflect information
                                            that had already been assessed and considered by management as part of its risk oversight
                                            processes at the time of the original filing. The omitted items resulted from an administrative
                                            omission during the final document compilation process and were not indicative of a deficiency
                                            in the Company’s underlying disclosure controls and procedures. The omission therefore
                                            did not result from a failure to identify or communicate material information to management,
                                            but rather from an administrative omission in the preparation of the final filing document.

2. Effectiveness
                                            of DCP: The Certifying Officers assessed whether the primary objective of DCP—to
                                            ensure that material information required to be disclosed was recorded, processed, summarized,
                                            and communicated to management to allow for timely decisions—was achieved. Despite
                                            the omissions identified in the amended final document, the underlying processes that feed
                                            into the Company’s disclosures (e.g., financial close, legal review, operational reporting)
                                            functioned effectively. All material financial and non-financial information required to
                                            be disclosed in the Form 20-F was identified and considered by management in preparing the
                                            original filing.

3. Post-Filing
                                            Remediation and Review: The identification of the omissions was a result of the Company’s
                                            internal post-filing review procedures and subsequent dialogue with the Staff. We determined
                                            that this was an isolated administrative omission that occurred during the final document
                                            assembly process. The Company has enhanced its final filing checklist and review procedures
                                            to further ensure that all required disclosure items and certifications are included in future
                                            filings.

  Based
                                            on the re-evaluation described above, management concluded that the omissions in the original
                                            filing did not result from a failure of the Company’s underlying disclosure controls
                                            and procedures to identify, record, process, summarize, or communicate material information
                                            to management on a timely basis. The omissions were considered an isolated administrative
                                            error in the final assembly of the filing document and did not stem from, nor did they constitute,
                                            a material weakness in the Company’s internal control over financial reporting or a
                                            failure of its disclosure controls and procedures to meet their stated objectives.

  Accordingly,
                                            management maintains its conclusion that the Company’s disclosure controls and procedures
                                            were effective in all material respects as of April 30, 2025.

Yours sincerely,

For and on behalf of

Magnitude International Ltd

/s/ Lim Say Wei

Lim Say Wei

Director & CEO