SecProbe.io

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 April 21, 2026

Ka Chun Gordon Li
General Manager
OneConstruction Group Ltd
Unit 11, 5/F, Tower 1, Harbour Centre
1 Hok Cheung Street
Hunghum, Kowloon, Hong Kong

 Re: OneConstruction Group Ltd
 Form 20-F for the Fiscal Year Ended March 31, 2025
 File No. 001-42457
Dear Ka Chun Gordon Li:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
</TEXT>
</DOCUMENT>

CORRESP
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 Loeb & Loeb LLP
 345 Park Avenue
 New York, NY 10154

 Direct +1
 212-407-4939
 Main +1
 212-407-4000
 Fax +1
 212-407-4990

 April 2, 2026

 Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, N.E. Washington, D.C. 20549

 Attention: Eric McPhee and Wilson Lee

 Re:

 OneConstruction Group Ltd (the "Company")
 Form 20-F for the Fiscal Year Ended March 31, 2025
 Response dated March 10, 2026
 File No. 001-42457

 Ladies and Gentlemen:

 This letter sets forth the Company's responses
to the comments contained in the letter dated March 24, 2026 from the staff (the "Staff") of the Securities and Exchange Commission
(the "Commission") regarding the Company's response dated March 10, 2026 to the SEC's initial comments to the
Company's annual report on Form 20-F for the fiscal year ended March 31, 2025, filed with the Commission on August 12, 2025 (the
"Form 20-F"). The Staff's comments are repeated below and followed by the Company's responses thereto.

 Form 20-F for the Fiscal Year Ended March 31, 2025

 Notes to Consolidated Financial Statements

 3. Concentration
of Risks, page F-12

 1.

 We note your response to comment 2.
 Please tell us what consideration you have given to disclosing information about your past due accounts receivables. Reference is
 made to the guidance outlined in paragraphs 326-20-55-37 through 40 of the Financial Accounting Standards Codification.

 RESPONSE: The Company respectfully advises the Staff
that it considered the guidance in ASC 326-20, including the illustrative Example 5 in paragraphs 55-37 through 55-40, in developing
its accounting policy for measuring expected credit losses on accounts receivable and determining the related disclosures. In evaluating
the need for additional disclosures regarding past-due accounts receivable, the Company specifically considered whether quantitative
aging disclosures or further qualitative discussion would be necessary to enable users to understand the credit risk profile of the portfolio,
consistent with ASC 326-20-50-2 and 50-3. This assessment included consideration of the proportion of past-due balances, historical collection
patterns, contractual payment structures, and whether past-due status is a meaningful indicator of credit deterioration in the Company's
business model.

 The Company's account receivable balance from customers
primarily arise from construction contracts that were still in progress as of the balance sheet date. The balance mainly represents progress
billings and retention sums that are contractually recoverable as project milestones are achieved and the projects move toward final account
settlement. Although certain amounts were classified as past due based on the original billing terms, management concluded, based on the
contractual rights and historical settlement patterns for similar projects, that such past-due status did not in itself indicate a significant
increase in credit risk or a heightened likelihood of loss. At the reporting date, management considered the credit quality of the customers,
the secured or otherwise supported nature of certain contracts and the continuing performance of the underlying projects in assessing
the collectability of the balance.

 In accordance with ASC 326-20, the Company estimates expected
credit losses for its accounts receivable on a collective basis for portfolios of receivables that share similar risk characteristics.
The estimation process incorporates an aging analysis of receivables, historical loss experience, customer-specific risk factors and forward-looking
macroeconomic and sector information, consistent with the concepts illustrated in ASC 326-20-55-37 through 55-40. In addition, in connection
with the preparation of the Company's financial statements, management engages an independent qualified valuer to assist in evaluating
the expected credit loss assumptions and results, including consideration of any changes in project status or customer creditworthiness.
This assistance supplements, but does not replace, management's overall responsibility for the expected credit loss estimates, which
are determined in accordance with ASC 326-20.

 2

 Based on this analysis, management has concluded that the
expected credit losses recognized in the allowance were appropriate, according to the latest 3-years historical settlement pattern from
our customers, our customers settled the past-due outstanding balance was approximately 77%, while the level of the past-due accounts
receivable as at March 31, 2025 was approximately 53% out of total gross accounts receivable, which was within the historical payment
pattern level, hence the management considered the past-due accounts receivable as at March 31, 2025 was at an acceptable level and considered
as not in significant risk to the consolidated financial statements taken as a whole. In making this assessment, the Company also considered
the disclosure framework in ASC 326-20-50-2 through 50-3, which focuses on enabling users to understand the credit risk inherent in the
portfolio, how management monitors credit quality, and how expected credit losses are estimated and change over time. The Company further
notes that all of its standard accounts receivable are contractually due within one year and therefore qualify for the exception in ASC
326-20-50-15, under which the specific requirement in ASC 326-20-50-14 to disclose past-due status by class does not apply to such short-term
accounts receivable that arise from revenue transactions. Although approximately 53% of receivables were classified as past due, management
determined that this metric is not indicative of increased credit risk due to the nature of construction contracts, including retention
arrangements and milestone-based billing. Historical data demonstrates consistent collection patterns, and past-due status primarily reflects
timing differences rather than credit deterioration.

 The Company acknowledges that the level of past-due receivables
may appear elevated; however, based on historical settlement experience and the contractual structure of such balances, management concluded
that additional disaggregation would not provide incremental decision-useful information beyond the disclosures already provided. On this
basis, the Company determined that a separate tabular disclosure of past-due accounts receivable was not required under U.S. GAAP and
that its existing disclosures regarding credit risk, allowance for expected credit losses and significant customers provided decision-useful
information to investors.

 In light of the Staff's comment, the Company will, in preparing its future Annual Reports on Form 20-F, continue to carefully consider
the applicable requirements of ASC 326-20 as well as relevant Commission and Staff guidance in order to provide disclosures in its consolidated
financial statements that are appropriate and sufficient for investors. The nature and extent of such disclosures will be determined based
on the facts and circumstances existing at the time and may include, but will not be limited to, additional qualitative and quantitative
information regarding accounts receivable, credit risk and expected credit losses, where such information is material to an understanding
of the Company's financial position and results of operations. The Company will consider enhancing future disclosures to include
additional qualitative or quantitative information regarding aging or past-due balances if such information becomes material or necessary
to provide a clearer understanding of credit risk trends.

 3

 Please do not hesitate to
contact Sherry Li at 212-407-4939 at Loeb & Loeb LLP with any questions or comments regarding this letter.

 Sincerely,

 /s/ Loeb & Loeb LLP

 Loeb & Loeb LLP

 cc: Ka Chun Gordon Li, General Manager

 Henry Yin, Loeb & Loeb LLP

 4

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<TEXT>
 March 24, 2026

Ka Chun Gordon Li
General Manager
OneConstruction Group Ltd
Unit 11, 5/F, Tower 1, Harbour Centre
1 Hok Cheung Street
Hunghum, Kowloon, Hong Kong

 Re: OneConstruction Group Ltd
 Form 20-F for the Fiscal Year Ended March 31, 2025
 Response dated March 10, 2026
 File No. 001-42457
Dear Ka Chun Gordon Li:

 We have reviewed your March 10, 2026 response to our comment letter and
have the
following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments. Unless
we note otherwise, any references to prior comments are to comments in our
February 12, 2026
letter.

Form 20-F for the Fiscal Year Ended March 31, 2025
Notes to Consolidated Financial Statements
3. Concentration of Risks, page F-12

1. We note your response to comment 2. Please tell us what consideration
you have given
 to disclosing information about your past due accounts receivables.
Reference is made to
 the guidance outlined in paragraphs 326-20-55-37 through 40 of the
Financial
 Accounting Standards Codification.
 Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468
if you have
questions regarding comments on the financial statements and related matters.
 March 24, 2026
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Real Estate & Construction
</TEXT>
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 Loeb & Loeb LLP
345 Park Avenue
New York, NY 10154

 Direct +1 212-407-4939

 Main +1 212-407-4000

 Fax +1 212-407-4990

 Via Edgar

 March 10, 2026

 Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, N.E. Washington, D.C. 20549

 Attention: Eric McPhee and Wilson Lee

 Re: OneConstruction Group Ltd (the "Company")
Form 20-F for the Fiscal Year Ended March 31, 2025
File No. 001-42457

 Ladies and Gentleman:

 This letter sets forth the Company's responses to the comments
contained in the letter dated February 12, 2026 from the staff (the "Staff") of the Securities and Exchange Commission (the
"Commission") regarding the Company's annual report on Form 20-F for the fiscal year ended March 31, 2025, filed with
the Commission on August 12, 2025 (the "Form 20-F"). The Staff's comments are repeated below and followed by the Company's
responses thereto.

 Form
20-F for the Fiscal Year Ended March 31, 2025

 Notes to the Consolidated Financial Statements

 2. Summary of Significant Accounting Policies

 Revenue Recognition, page F-9

 1. We note your discussion of defects liability periods on page 43. Please tell us what consideration you gave to addressing your
accounting policy for defects liability periods within your revenue recognition policy.

 RESPONSE: The Company respectfully advises the Staff that with respect to the
defects liability period, the clients of the Company's operating subsidiary may retain up to 5% to 10% of each payment to be made to the
operating subsidiary, as retention monies. The defects liability period does not represent a separate performance obligation and therefore
does not impact the timing of revenue recognition. The defects liability period is merely a warranty in nature, and it is not an additional
service provided to the customer. It does not increase the scope of work done in a construction project, and does not constitute a distinct
service.

 Revenue is recognized when the construction
work services were performed over prescribed periods specified within the contract with the customer. Please see Note 2 to the consolidated
financial statements in the Company's Form 20-F.

 A receivable is recorded when the Group
has an unconditional right to consideration. A right to consideration is unconditional if only the passage of time is required before
payment of that consideration is due. Please see Note 2 to the consolidated financial statements in the Company's Form 20-F. The
Group records retention as a "Retention Receivable" under Accounts Receivable of current assets when a progress invoice is
submitted, separating it from the standard accounts receivable in Note 10 to the consolidated financial statements in the Company's
Form 20-F.

 Retention amounts are classified as accounts receivable because the
Group has an unconditional right to consideration, as only the passage of time and the completion of the defects liability period are
required for payment to become due. Upon completion of the construction project and after the defects liability period, the retentions
are then released from the Retention receivable account to standard accounts receivable account. Provided that during the defects liability
period, any loss considered as probable and the amount of loss considered as reasonably estimated, the retention shall be immediately
released and recorded as expense in the profit or loss account in accordance with ASC 450.

 Los
Angeles New York Chicago Nashville
Washington, DC San Francisco Tysons Beijing Hong
Kong www.loeb.com

 For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

 Division of Corporation Finance

 March 10, 2026

 Page 2

 3. Concentration of Risks, page F-12

 2. We note that over 38% of your accounts receivable balance as of March 31, 2025, $8.9M, is due from a single customer, and that
your revenues from that customer during the 12 months ended March 31, 2025 were only $1.8M. Please clarify whether any amounts due from
this customer were past due as of March 31, 2025, and if these amounts have been subsequently collected. To the extent any of these amounts
remain outstanding as of September 30, 2025, please tell us if you have recorded any credit loss allowance.

 RESPONSE: The Company respectfully advises the Staff
that the accounts receivable balance from the customer in question included amounts that were past due as of March 31, 2025. The Company
has subsequently collected a significant portion of this balance.

 Specifically, the aging of the gross accounts receivable
of $8,888,000 from this customer as of March 31, 2025, was as follows:

 Not yet past due:
 $ 1,340,000

 Past due over 180 days but within 1 year:
 $ 3,841,000

 Past due over 1 year but within 2 years:
 $ 3,707,000

 Total Gross Accounts Receivable:
 $ 8,888,000

 As of March 31, 2025, the Company had recorded an allowance
for credit loss of $148,000 against this receivable, resulting in a net accounts receivable balance of $8,740,000.

 Regarding subsequent collection, between March 31, 2025,
and September 30, 2025, the Company collected $5,665,000 from this customer. As of September 30, 2025, the outstanding gross accounts
receivable from this customer was reduced to $3,223,000. The aging of this remaining balance was as follows:

 Not yet past due:
 $ 1,340,000

 Past due over 1 year but within 2 years:
 $ 1,883,000

 Total Gross Accounts Receivable:
 $ 3,223,000

 For the remaining outstanding amount as of September 30,
2025, the Company maintained an allowance for credit loss on accounts receivable of $27,000, resulting in a net accounts receivable balance
of $3,196,000.

 Division of Corporation Finance

 March 10, 2026

 Page 3

 Please do not hesitate to contact Sherry Li at
212-407-4939 at Loeb & Loeb LLP with any questions or comments regarding this letter.

 Sincerely,

 /s/ Loeb & Loeb LLP

 Loeb & Loeb LLP

 cc: Ka Chun Gordon Li, General Manager

 Henry Yin, Loeb & Loeb LLP

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 February 12, 2026

Ka Chun Gordon Li
General Manager
OneConstruction Group Ltd
Unit 11, 5/F, Tower 1, Harbour Centre
1 Hok Cheung Street
Hunghum, Kowloon, Hong Kong

 Re: OneConstruction Group Ltd
 Form 20-F for the Fiscal Year Ended March 31, 2025
 File No. 001-42457
Dear Ka Chun Gordon Li:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year Ended March 31, 2025
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-9

1. We note your discussion of defects liability periods on page 43. Please
tell us what
 consideration you gave to addressing your accounting policy for defects
liability periods
 within your revenue recognition policy.
3. Concentration of Risks, page F-12

2. We note that over 38% of your accounts receivable balance as of March
31, 2025,
 $8.9M, is due from a single customer, and that your revenues from that
customer during
 the 12 months ended March 31, 2025 were only $1.8M. Please clarify
whether any
 amounts due from this customer were past due as of March 31, 2025, and
if these
 amounts have been subsequently collected. To the extent any of these
amounts remain
 outstanding as of September 30, 2025, please tell us if you have
recorded any credit loss
 allowance.
 February 12, 2026
Page 2

 In closing, 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.

 Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468
with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
</TEXT>
</DOCUMENT>

CORRESP
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 OneConstruction Group Limited

 April 10, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, DC 20549

 Re:

 OneConstruction Group Limited
 Registration Statement on Form F-1, as amended
 (File No. 333-286360)
 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461 of the General Rules
and Regulations under the Securities Act of 1933, as amended, OneConstruction Group Limited hereby requests an acceleration of the effectiveness
of the above-referenced Registration Statement on Form F-1, as amended, so that such Registration Statement will become effective at 4:00
p.m., Eastern Time, on April 11, 2025, or as soon thereafter as practicable.

 The Company understands that the Commission will
consider this request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the Company
is aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the securities specified in
the Registration Statement.

 Very truly yours,

 /s/ Ka Chun Gordon Li

 Name:
 Ka Chun Gordon Li

 Title:
 General Manager
 (Principal Executive Officer)

CORRESP
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 Concord & Sage PC

 April 7, 2025

 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:
 Benjamin Holt

 Pam Howell

 Re:
 OneConstruction Group Limited

 Form F-1

 Submitted April 7, 2025
 CIK No. 0002030834

 Ladies and Gentlemen:

 On behalf of our client, OneConstruction
Group Limited, a foreign private issuer organized under the laws of the Cayman Islands (the " Company "), we are submitting
this letter to the staff (the " Staff ") of the Securities
and Exchange Commission (the " Commission ") in response to the comments contained in the Staff's letter dated
April 4, 2025 regarding the Company's draft registration statement on Form F-1 submitted on April 3, 2025. Concurrently with the
submission of this letter, the Company is submitting its revised registration statement on Form F-1 (the " Revised
Registration Statement ") and certain exhibits via EDGAR to the Commission. The Revised Registration Statement has been
updated to fully comply with Form F-1 requirements by including all necessary information directly.

 The Staff's comments
from its letter dated April 4, 2025 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 Registration Statement where the language addressing the comments appears. Capitalized terms used
but not otherwise defined herein have the meanings set forth in the Revised Registration Statement.

 Registration Statement on Form F-1 filed April
3, 2025

 Management

 Compensation of Directors and Executive Officers,
page 84

 1.
 Please revise to provide compensation for the last full financial year, March 31, 2025, as required by Item 6.B of Form 20-F.

 In response to the Staff's comment, the Company has revised the referenced disclosure on page 84 of the Revised Registration Statement.

 Management

 Compensation of Directors and Executive Officers,
page 84

 Concord & Sage PC. Email: info@concordsage.com

 1360 Valley Vista Dr, Suite 140, Diamond Bar CA 91765

 Very truly yours,

 /s/ Kyle Leung

 Name:
 Kyle Leung

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<TEXT>
 April 4, 2025

Ka Chun Gordon Li
General Manager
OneConstruction Group Limited
Room 6808A, 68/F
Central Plaza
18 Harbor Road
Wanchai, Hong Kong

 Re: OneConstruction Group Limited
 Registration Statement on Form F-1
 Filed April 3, 2025
 File No. 333-286360
Dear Ka Chun Gordon Li:

 We have reviewed your registration statement and have the following
comment.

 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 F-1 filed April 3, 2025
Management
Compensation of Directors and Executive Officers, page 84

1. Please revise to provide provide compensation for the last full
financial year, March
 31, 2025, as required by Item 6.B of Form 20-F.

 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.
 April 4, 2025
Page 2

 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.

 Please contact Benjamin Holt at 202-551-6614 or Pam Howell at
202-551-3357 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Kyle Leung
</TEXT>
</DOCUMENT>

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 Concord & Sage PC

 April 3, 2025

 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:

 Benjamin Holt

 Pam Howell

 Re:

 OneConstruction Group Limited

 Form F-1

 Submitted April 3, 2025
 CIK No. 0002030834

 Ladies and Gentlemen:

 On behalf of our client, OneConstruction
Group Limited, a foreign private issuer organized under the laws of the Cayman Islands (the " Company "), we are submitting
this letter to the staff (the "Staff") of the Securities and Exchange Commission (the " Commission ") in
response to the comments regarding the Company's draft registration statement on Form F-1 submitted on March 12, 2025. Concurrently
with the submission of this letter, the Company is submitting its revised registration statement on Form F-1 (the "Revised Registration
Statement"). The Revised Registration Statement has been updated to fully comply with Form F-1 requirements by including all necessary
information directly.

 In response to the Staff's
comments, we have revised our disclosure in the Management Section on page 84 to include the Compensation of Directors and Executive Officers
for the year ended March 31, 2024.

 Concord & Sage PC. Email: info@concordsage.com

 1360 Valley Vista Dr, Suite 140, Diamond Bar CA 91765

 Very truly yours,

 /s/ Kyle Leung

 Name:
 Kyle Leung

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 March 21, 2025

Ka Chun Gordon Li
General Manager
OneConstruction Group Limited
Room 6808A, 68/F
Central Plaza
18 Harbor Road
Wanchai, Hong Kong

 Re: OneConstruction Group Limited
 Draft Registration Statement on Form F-1
 Submitted March 12, 2025
 CIK No. 0002030834
Dear Ka Chun Gordon Li:

 We have reviewed your draft registration statement and have the
following comment.

 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.

Draft Registration Statement on Form F-1 submitted March 12, 2025
General

1. Please revise to provide all of the information required by Form F-1. We
note that you
 have attempted to incorporate by reference the information from your
initial public
 offering Form F-1. However, you are not eligible to use incorporation by
reference
 because you do not meet the requirements of General Instruction VI.C.
and D.1.(c) of
 Form F-1.
 March 21, 2025
Page 2

 Please contact Benjamin Holt at 202-551-6614 or Pam Howell at
202-551-3357 with
any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Real Estate &
Construction
cc: Kyle Leung
</TEXT>
</DOCUMENT>

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OneConstruction Group Limited

Room 6808A, 68/F,

Central Plaza,

18 Harbor Road,

Wanchai, Hong Kong

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, NE

Washington, D.C., 20549

    Attention:

    Shannon Menjivar

    Howard Efron

    Pam Long

    Benjamin Holt

December 20, 2024

    Re:
    OneConstruction Group Limited

    Registration Statement on Form F-1 (File No. 333-283186)

    Initially Filed on November 13, 2024

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, OneConstruction Group Limited (the “Company”) hereby requests acceleration of effectiveness of the above
referenced Registration Statement, so that it will become effective at 5:00 p.m., Eastern Time, on December 20, 2024, or as soon as thereafter
practicable.

Very truly yours,

    /s/ Ka Chun Gordon Li

    Name: Ka Chun Gordon Li

    Title: General Manager

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC

CORRESP
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December 20, 2024

VIA EDGAR

Division of Corporation Finance

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn:
Pam Long

Benjamin Holt

    Re:
    OneConstruction Group Limited (CIK No. 0002030834)

    Request for Acceleration

    Registratio Statement on Form F-1, as amended (File No.
                                                     333-283186)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and
Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, American Trust Investment Services,
Inc. and WestPark Capital, Inc. as representatives of the underwriters, hereby request acceleration of the effective date of the above-referenced
Registration Statement so that it will become effective at 5:00 p.m., Eastern Time on Friday, December 20th, 2024, or as soon
thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to
advise you that we have distributed as many copies of the Prospectus dated December 20, 2024, to selected dealers, institutions and others
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

The undersigned confirm that they have complied
and will continue to comply with, and they have been informed or will be informed by participating dealers that they have complied or
will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above-referenced
issue.

Very truly yours,

American Trust Investment Services, Inc.

    By:
    /s/ Kristopher Kessler

    Name:
    Kristopher Kessler

    Title:
    Managing Principal

WestPark Capital, Inc.

    By:
    /s/ Richard Rappaport

    Name:
    Richard Rappaport

    Title:
    Chief Executive Officer

September 24, 2024
Kam Cheung Cheung
Executive Director
OneConstruction Group Limited
Room 6808A, 68/F
Central Plaza
18 Harbor Road
Wanchai, Hong Kong
Re:OneConstruction Group Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 11, 2024
CIK No. 0002030834
Dear Kam Cheung Cheung:
            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 August 29,
2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted September 11, 2024
Prospectus Summary
Summary of Risk Factors, page 15
We note your response to prior comment 2. Where you summarize the risks relating to
doing business in Hong Kong, please revise to highlight that any actions by the Chinese
government to exert more oversight and control over offerings that are conducted
overseas and/or foreign investment in China-based issuers could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless, as you explain 1.

September 24, 2024
Page 2
on page 18. Please also include a cross-reference to your page 18 risk factor, " If the PRC
government chooses to exert more oversight and control . . . ."
Related Party Transactions, page 100
2.We note your response to prior comment 12. For the loan due to a related company,
please further revise to disclose the largest amount outstanding during the period covered,
the amount outstanding as of the latest practicable date, and the nature of the loan and the
transaction in which it was incurred. Refer to Item 7.B.2 of Form 20-F
            Please contact Howard Efron at 202-551-3439 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Holt at 202-551-6614 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Ying Li, Esq.

August 29, 2024
Kam Cheung Cheung
Executive Director
OneConstruction Group Limited
Room 6808A, 68/F
Central Plaza
18 Harbor Road
Wanchai, Hong Kong
Re:OneConstruction Group Limited
Draft Registration Statement on Form F-1
Submitted August 2, 2024
CIK No. 0002030834
Dear Kam Cheung Cheung:
            We have reviewed your 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.
Draft Registration Statement on Form F-1 submitted August 2, 2024
Cover Page
1.Please revise to clearly state the location of your auditor's headquarters. Please also revise
here and elsewhere where you discuss the HFCA Act to reconcile your disclosures
regarding the location of your auditor's headquarters. For example, we note your cross-
reference to the risk factor on page 25, "Although the audit report included in this
prospectus is prepared by U.S. auditors who are currently inspected by the PCAOB . . . ,"
which indicates that Audit Alliance LLP is headquartered in the U.S. However, you state
elsewhere that Audit Alliance LLP is headquartered in Singapore. We note similar
inconsistent references to Audit Alliance LLP being U.S. auditors or a U.S.-based
accounting firm on pages 8, 25, and 26.

August 29, 2024
Page 2
Prospectus Summary
Summary of Risk Factors, page 7
2.Please revise your Summary of Risk Factors so that it is no more than two pages. Also
move the Summary of Risk Factors so that they immediately precede the Risk Factors
section that begins on page 21. See Item 3 of Form F-1 and Item 105(b) of Regulation S-
K.
Recent Regulatory Developments in the PRC, page 13
3.We refer to your statement on page 15 that you do not currently expect, among other laws
and regulations, the Draft Overseas Listing Regulations to have an impact on your
business, operations, or this offering. Please revise to also state whether you expect
the Trial Measures, together with the Guidance Rules and Notice, to have an impact on
your business, operations, or this offering.
Implications of Being an Emerging Growth Company and a Foreign Private Issuer, page 18
4.Please revise here and your risk factor on page 46, "As a foreign private issuer, we are
permitted to adopt certain home country practices in relation to corporate governance
matters . . .," to clarify whether you intend to follow home country corporate governance
practices. To the extent that you intend to follow home country corporate governance
practices, please revise your disclosure to identify such practices and briefly explain how
they differ from the corporate governance requirements of Nasdaq.
Risk Factors
Risks Related to Our Business and Industry
Delay in the commencement and progress of public projects . . ., page 37
5.Please revise to disclose whether, during the fiscal years ended March 31, 2023 and 2024,
you experienced delays in the commencement and/or progress of public projects that had
a material impact on your business, financial condition, or results of operations.
Use of Proceeds, page 56
6.We note that the allocation of proceeds of the offering to working capital or general
corporate purposes is based on your present plans. Please revise to discuss any specific
principal intended uses for the proceeds of this offering, and identify, if known, the
approximate amount of proceeds you intend to use for such specific purposes. For
example, we note disclosure on page 78 that as part of your growth strategy you intend to
use a portion of net proceeds for up-front costs for future projects and that you currently
plan to hire additional project managers, quantity surveyors and engineers after the
offering. We also note that you have bank borrowings and loans from a related party, as
disclosed on pages 71 and 72. If you will use proceeds of this offering to repay all or a
portion of these borrowings, please also disclose this and include the additional
information required by Item 3.C.4 of Form 20-F.

August 29, 2024
Page 3
Management's Discussion and Analysis of Financial Condition and Results of Operations
Comparison of Fiscal Years Ended March 31, 2023 and March 31, 2024
Cost of revenue, page 67
7.Please revise to identify and briefly discuss the drivers of material variances in each of the
individual components of your cost of revenue. For example, we note that costs for
procuring materials decreased year-over-year by approximately 18%. However, your
disclosure elsewhere, such as your risk factor on page 36 regarding the shortage or
increase in global steel prices, suggests that costs for procuring materials would be
expected to increase year-over-year.
Liquidity and Capital Resources, page 70
8.Please revise to provide all the information required by Item 5.B of Form 20-F,
including material cash requirements from indebtedness and other obligations. For
example, we note your disclosure on pages 71-72 regarding cash generated from
financing activities, including net proceeds from a loan due to a related company of
$1,517,000 and $4,885,000 during the fiscal years ended March 31, 2023 and 2024,
respectively. Please also file as exhibits the agreements or contracts made in
connection with the loan. Refer to Item 601(b)(10) of Regulation S-K.
Trend Information, page 72
9.We note your statement that you are not aware of any trends, uncertainties, demands,
commitments or events that are reasonably likely to have a material effect on you. Please
tell us what consideration you have given to whether the items described under "Market
Challenges and Threats" on pages 52 and 53 may be reasonably like to have a material
effect on your net sales or revenues, income from continuing operations, profitability,
liquidity or capital resources, or would cause reported financial information not
necessarily to be indicative of future operating results or financial condition.
Business, page 75
10.Please revise to disclose OneC Engineering's registrations as a Registered Specialist Trade
Contractor for Concreting and Reinforcement Bar Fixing, as you discuss on page 96.
Specify when, if at all, such registrations expire and briefly discuss how you monitor
OneC Engineering's continued compliance with the requirements of these registrations.
Please also revise to disclose that OneC Engineering, as a subcontractor, relies on the
general contractor's registration as a Registered General Building Contractor, as you
discuss on page 91.
11.Please revise your discussion of the principal steps in a project and approximate project
timeframe, as applicable, to highlight whether or how delays may impact the operating
subsidiary's operations and results of operations. In this regard, we note that the majority
of your revenue is derived from public sector projects and you discuss various factors that
may cause delays to public sector projects, including on pages 37 and 52, such as political
disagreements or filibustering, objections or legal actions by the public, and fiscal deficits
or budget cuts.

August 29, 2024
Page 4
Related Party Transactions, page 103
12.Please revise to provide all the information required by Item 7B. of Form 20-F. For
example, we note your disclosure in Note 18. Related Party Transactions on page F-22
regarding the loan due to a related company. Please also file as exhibits the agreements
or contracts made in connection with related party transactions, as applicable. Refer to
Item 601(b)(10) of Regulation S-K.
General
13.Where you discuss the legal and operational risks associated with being based in and
having the majority of your operations in China (including Hong Kong), please revise to
discuss the commensurate laws and regulations in Hong Kong and any risks and
consequences to you and/or the operating subsidiary associated with these laws and
regulations. For example, disclose on the cover page how any regulatory actions related to
data security or anti-monopoly concerns in Hong Kong have or may impact the
company’s ability to conduct its business, accept foreign investments, or list on a U.S. or
foreign exchange. Also provide risk factor disclosure to explain whether there are any
commensurate laws or regulations in Hong Kong which result in oversight over data
security and explain how this oversight impacts the company’s business and the offering
and to what extent the company believes that it is compliant with the regulations or
policies that have been issued.
14.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.
            Please contact Howard Efron at 202-551-3439 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Benjamin Holt at 202-551-6614 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Ying Li, Esq.