March 3, 2020

William Coote
Interim Chief Financial Officer
TARO PHARMACEUTICAL INDUSTRIES LTD
3 Skyline Drive
Hawthorne, New York 10532

       Re: TARO PHARMACEUTICAL INDUSTRIES LTD
           Form 20-F for Fiscal Year Ended March 31, 2019
           Filed June 20, 2019
           File No. 001-35463
           Response Dated February 20, 2020

Dear Mr. Coote:

        We have reviewed your February 20, 2020 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please
tell us why in
your response. After reviewing your response to this comment, we may have
additional
comments.

Form 20-F for Fiscal Year Ended March 31, 2019

Note 2: - Significant Accounting Policies
b. Financial statements in U.S. dollars, page F-12

1.     Please address each indicator identified in ASC 830-10-55-5 and tell us
whether it
       suggested CAD or USD as your functional currency for your initial
assessment versus the
       assessment adopted on April 1, 2019, and how each indicator was
weighted. Clarify the
       significant changed economic facts and circumstances underlying each
changed indicator.
       You may contact Tracey Houser at (202) 551-3736, or Jeanne Baker at
(202) 551-3691, if
you have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
 William Coote
TARO PHARMACEUTICAL INDUSTRIES LTD
FirstName LastNameWilliam Coote
March 3, 2020
Page 2
Comapany NameTARO PHARMACEUTICAL INDUSTRIES LTD
March 3, 2020 Page 2                     Office of Life Sciences
FirstName LastName