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                            April 16, 2024

       Brandon Robinson
       Chief Executive Officer
       New Horizon Aircraft Ltd.
       3187 Highway 35
       Lindsay, Ontario, K9V 4R1

                                                        Re: New Horizon
Aircraft Ltd.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed on April 8,
2024
                                                            File No. 333-277063

       Dear Brandon Robinson:

              We have conducted a limited review of 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.

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

       MD&A, page 49

   1.                                                   Please revise the MD&A
section to cover the periods covered by the financial statements
                                                        of New Horizon Aircraft
Ltd. that are included in the registration statement.
               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.

              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 Bradley Ecker at 202-551-4985 or Evan Ewing at
202-551-5920 with
       any questions.
 Brandon Robinson
New Horizon Aircraft Ltd.
April 16, 2024
Page 2




FirstName LastNameBrandon Robinson       Sincerely,
Comapany NameNew Horizon Aircraft Ltd.
                                         Division of Corporation Finance
April 16, 2024 Page 2                    Office of Manufacturing
FirstName LastName