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                            March 17, 2023

       Robert Wiley
       Chief Financial Officer
       AMMO, INC.
       7681 E. Gray Road
       Scottsdale, AZ 85260

                                                        Re: AMMO, INC.
                                                            Form 10-Q for the
period ended December 31, 2022
                                                            Filed February 14,
2023
                                                            Form 8-K
                                                            Filed February 14,
2023
                                                            File No. 001-13101
                                                            Response Dated
March 3, 2023

       Dear Robert Wiley:

              We have reviewed your March 3, 2023 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       February 1, 2023 letter.

       Form 10-Q for the period ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 26

   1.                                                   We note your responses
to prior comments 1 and 2, including the revisions to the non-
                                                        GAAP financial measure
you identify as Adjusted EBITDA. We note the revised
                                                        measure appears to
include an adjustment for the tax effect of other non-GAAP
                                                        adjustments. Since
Adjusted EBITDA is a pre-tax non-GAAP performance measure, it is
                                                        not clear why it is
appropriate to include an adjustment for the tax effect of other non-
                                                        GAAP adjustments.
Please more fully explain the updated measure or revise it. This
 Robert Wiley
AMMO, INC.
March 17, 2023
Page 2
         comment is also applicable to the presentation of Adjusted EBITDA in
the earnings
         release you filed under Form 8-K on February 14, 2023.
Form 8-K filed on February 14, 2023

Exhibit 99.1
Non-GAAP Financial Measures, page 8

2.       We note your responses to prior comments 1 and 2, including the
revisions to the non-
         GAAP financial measures you identify as Adjusted EBITDA, Adjusted Net
Income, and
         Adjusted Earnings Per Share. We note in addition to presenting updated
non-GAAP
         financial measures, you continue to present historical non-GAAP
financial measures
         based on how each measure was previously calculated. It appears to us
your current
         presentation is not appropriate and confusing. As our prior comments
indicated, your
         historical non-GAAP financial measures did not comply with Item 10(e)
of Regulation S-
         K and the related CD&Is. We believe non-GAAP financial measures should
be
         consistently presented for each period presented and, if applicable,
you should disclose
         and discuss any changes in how measures are calculated relative to
historical measures;
         however, we do not believe continuing to present inappropriate
historical measures is
         appropriate. Please more fully explain your current presentation or
revise it to eliminate
         historical non-GAAP financial measures.
3.       We note your response to prior comment 1, including the revisions to
the non-GAAP
         financial measures you identify as Adjusted Net Income and Adjusted
Earnings Per Share
         and the revised disclosure that tax effects are computed at statutory
rates; however, it is
         not clear how the tax effects are actually determined. For example,
based on the
         magnitude of the non-GAAP adjustments to Adjusted Net Income and
Adjusted Earnings
         Per share during the three months ended December 31, 2021 and the nine
months ended
         December 31, 2021, it is not clear why the tax effects are essentially
the same in both
         periods. Please explain or revise.
        You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at
(202) 551-
3709 if you have questions regarding comments on the financial statements and
related matters.



FirstName LastNameRobert Wiley                                Sincerely,
Comapany NameAMMO, INC.
                                                              Division of
Corporation Finance
March 17, 2023 Page 2                                         Office of
Manufacturing
FirstName LastName