March 29, 2019

Joseph Macaluso
Principal Accounting Officer
Tel-Instrument Electronics Corp.
One Branca Road
East Rutherford, NJ 07073

       Re: Tel-Instrument Electronics Corp
           Form 10-K for the Fiscal Year Ended March 31, 2018
           Filed July 16, 2018
           File No. 001-31990

Dear Mr. Macaluso:

       We have reviewed your filing and have the following comment. 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 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 10-K for the Fiscal Year Ended March 31, 2018

Item 9A. Controls and Procedures, page 49

1.    Consistent with Item 307 of Regulation S-K, please amend the filing to
disclose the
      conclusion of your principal executive and principal financial officers
regarding the
      effectiveness of your disclosure controls and procedures as of the end of
the period
      covered by the report - i.e., March 31, 2018.


        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.
 Joseph Macaluso
Tel-Instrument Electronics Corp.
March 29, 2019
Page 2

      Please contact Tara Harkins at 202-551-3639 or Lynn Dicker, Senior
Accountant, at 202-
551-3616 with any questions.



FirstName LastNameJoseph Macaluso                        Sincerely,
Comapany NameTel-Instrument Electronics Corp.
                                                         Division of
Corporation Finance
March 29, 2019 Page 2                                    Office of Electronics
and Machinery
FirstName LastName