SecProbe.io

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

<DOCUMENT>
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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

<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 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.