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                            May 25, 2023

       Mohan Ananda
       Chief Executive Officer
       Innovative International Acquisition Corp.
       24681 La Plaza Ste 300
       Dana Point, CA 92629

                                                        Re: Innovative
International Acquisition Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed April 27,
2023
                                                            File No. 333-269627

       Dear Mohan Ananda:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
6, 2023 letter.

       Amendment No. 1 to Registration Statement on Form S-4

       Comparative Per Share Information, page 51

   1.                                                   We note your response
to comment 7. Please revise to include disclosure indicating that
                                                        your calculation of
historical book value per share includes both temporary equity and
                                                        permanent equity.
   2.                                                   Please explain in
further detail how you calculated the Zoomcar equivalent pro forma per
                                                        share data as we are
unable to calculate these amounts based on the Exchange Ratio of
                                                        .0464 disclosed in
footnote (1) to the table.
 Mohan Ananda
FirstName
Innovative LastNameMohan    AnandaCorp.
           International Acquisition
Comapany
May        NameInnovative International Acquisition Corp.
     25, 2023
May 25,
Page 2 2023 Page 2
FirstName LastName
Description of Negotiation Process with Zoomcar, page 115

3.       We note your disclosure that "IOAC took several rounds of discussions
before proposing
         an initial term sheet," as well as that "[o]n July 1, 2022, IOAC, in
consultation with
         representatives of CCM and representatives of IOAC   s U.S. legal
counsel, McDermott
         Will & Emery (   MWE   ), sent Zoomcar an initial draft term
sheet...." Please revise to
         disclose the nature and major issues discussed in these "several
rounds of discussions"
         prior to the July 1, 2022 presentation of an initial term sheet.
Zoomcar Inc. Interim Financial Statements
27 Variable Interest Entities, page F-97

4.       We note the disclosures added to your interim financial statements in
response to
         comment 21. Please revise the notes to your audited financial
statements to also include
         the applicable disclosures required by ASC 810-10-50.
Exhibit 5.1

5.       Based on Exhibit 107, it appears that the registration statement
covers 95,887,829 shares
         of common stock and 11,500,000 warrants to purchase common stock,
however the legal
         opinion covers 65,760,335 shares of common stock and 11,500,000
warrants to purchase
         common stock. Please revise the opinion to cover all of the securities
that are covered by
         the registration statement, or advise.
Exhibit 8.1

6.       It appears that Exhibit 8.1 is intended to serve as a "short-form
opinion" per Section III.B
         of Staff Legal Bulletin No. 19. Please revise the tax opinion to state
that the disclosure in
         the "Material U.S. Federal Income Tax Consequences to Redemption"
section of the
         prospectus is the opinion of McDermott Will & Emery LLP. In addition,
please revise the
         assumption in the third paragraph that all documents have been/will be
duly executed and
         delivered to exclude IOAC/Zoomcar.
General

7.       Where you state that the Sponsor entered into the sponsor support
agreement, please
         clarify, if true, that no other consideration was exchanged in regard
to such agreement.
 Mohan Ananda
FirstName
Innovative LastNameMohan    AnandaCorp.
           International Acquisition
Comapany
May        NameInnovative International Acquisition Corp.
     25, 2023
May 25,
Page 3 2023 Page 3
FirstName LastName
       You may contact Abe Friedman at 202-551-8298 or Linda Cvrkel at
202-551-3813 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222 with
any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services