SecProbe.io

June 26, 2012

China Green Agriculture, Inc.
Mr. Ken Ren
Chief Financial Officer
3 rd Floor, Borough A, Block A, No. 181
South Taibai Road, Xi’an, Shaanxi Province
People’s Republic of China 710065

Re: China Green Agriculture, Inc.
 Form 10-K for the Fiscal Year E nded June 30, 2011
Filed September 12, 2011
File No. 001 -34260

Form 10 -Q for the Quarterly Period Ended March 31, 2012
Filed May 10, 2012
File No. 001 -34260

Dear Mr. Ren :

We have reviewed your filing an d 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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   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 respons e.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2011

Item 1A. Risk Factors

1. Reference is made to your di scussion of the financial performance of Gufeng on page 28.
Please reconcile for us the $11,422,057 net income for the fiscal year ended June 30, 2011 as
quoted in your discussion with the $10,995,984 as stated in Footnote 16 to the financial
statements p resented on page F -23.

Ken Ren
China Green Agriculture, Inc.
June 26, 2012
Page 2

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Recent Developments

New Products, page 47
2. Please clarify to us in your response and revise future filings to indicate the proportion of
revenue that is attributable both to new products and new distributors.

Results of Operations

Net Sales, page 49
3. Refer to the third paragraph of your narrative.  We note that you have included a comparative
discussion of Gufeng’s  net sales from fiscal 2011 to fiscal 2010.  Gufeng has not been
included in your financial statements for the year ended June 30, 2010 as it was acquired in
July 2010. Further, Gufeng’s latest fiscal year prior to acquisition ended on December 31,
2009.  As such, the annualized net sales figure for Gufeng for the year ended June 30, 2010
appears to be a pro forma presentation of net sales with no supporting explanation or
calculation prepared in accordance with Article 11 of Regulation S -X. Please remove t he
reference to Gufeng’s net sales for the fiscal year ended June 30, 2010 as its inclusion is
neither necessary nor appropriate.

Discussion of Segment Profitability Measures, page 53
4. In Footnote 16, you present both operating income and net income by ope rating segment.
Please clearly identify, here and in your footnote, the specific measure of segment
profitability or loss that is reported to the chief operating decision maker for purposes of
making decisions about allocating resources to the segment and  assessing its performance.
Refer to ASC 280 -10-50-27 for guidance.

5. In addition, please expand this discussion to also address significant changes in that measure
on a comparative basis for fiscal 2011 compared to fiscal 2010 and for fiscal 2010 compared
to fiscal 2009.  In this regard, we are particularly concerned as to the nature of and reasons
for the significant negative variance in the profitability of Jintai in fiscal 2011.  Please
address this development in your response  in detail.  You should al so indicate whether this
trend is expected to continue.  If significant write -offs were taken, please describe and
quantify them and tell us how they were classified.  Our comment applies to the disclosures
in your Form 10 -Q for the Quarterly Period Ended March 31, 2012 as well.  We may have
further comments upon review of your response.

Ken Ren
China Green Agriculture, Inc.
June 26, 2012
Page 3

 Financial Statements

Note 2 – Basis of Presentation and Summary of Significant Accounting Policies

6. Reference is made to the apparent significance of your research and development
expenditures as described on page 17.  Please explain to us, and disclose, how research and
development costs are accounted for and classified and how the elements of costs are
identified with your related activities.  Quantitative disclosu res are also required under ASC
730-10-50-1.  Alternatively, please identify the location of these disclosures in your
footnotes.

7. We note the very significant increase in advances to suppliers as of June 30, 2011.  Please
describe the significant contract ual terms of these arrangements in expanded detail and tell us
about the nature and composition of these balances.  Please also describe the extent to which
these balances are seasonal, if applicable.  Finally, these balances appear significantly larger
than the advances in the historical financial statements of Gufeng.  If our understanding is
correct, please explain why this is the case.  We also note that you have recorded a related
allowance of $549,470 in fiscal 2011.  Please explain how and when this charge was
determined and recorded.  Finally, please expand your footnotes to address this account.

8. As a related matter, it appears from page 55 that your advance payments to suppliers are
made to insure that future product will be shipped to you when nee ded.  Please explain to us
how and why the business of Gufeng also results in the generation of significant balances of
unearned revenues.

9. It appears, from your most recently filed Definitive Proxy that you have a related party
relationship with a company called Kingtone Information.  If our understanding is correct,
please indicate the location of any related disclosures provided in the foot notes.
Alternatively, please explain why you believe that no related disclosures are required.

Note 7 – Land Use Right, page F -14

10. We note from your disclosure in Risk Factors on page 28 that you have legally not obtained
the land use right over the premises on which certain facilities of Gufeng are located and, as a
result, you may not have the right to use the premises or the buildings located thereon.
Please tell us in your response how the land use right i n question and the buildings and
improvements built thereon were valued and recorded at the time of the transaction and how
such valuation was reassessed, if necessary, at the time you discovered you had not obtained
the land use right .

11. As a related mat ter, please tell us the proportion of facilities potentially impacted by the
validity of the land use right.  In your response, discuss the specific properties identified on
pages 38 -39 as relating to Gufeng, including the proportion of total and utilized
manufacturing square meters, impacted by this issue.

Ken Ren
China Green Agriculture, Inc.
June 26, 2012
Page 4

 Note 16. Segment Reporting, page F -22

12. Reference is made to your discussion of exports on page 14.  It appears that related
disclosures are required in the footnotes under ASC 280 -10-50-41(a).  Please pr ovide this
disclosure or explain why the requirement is not applicable.

Form 10 -Q for the Quarterly Period Ended March 31, 2012

Item 1. Financial Statements

Condensed Consolidated Balance Sheets, page 3

13. We note from your presentation here that your acc ounts receivable balance has increased
$42.9 million between June 30, 2011 and March 31, 2012 , more than the entire $39.3 million
in inco me from operations for the same period.  Further, the increase of $42.9 million
represents 74% of gross profit and 27% of net sales for that nine-month period.  Your
disclosure on page 29 indicates that your allowance, which represented less than 1% of total
receivables at March 31, 2012, increased only 78.4% versus the 244% increase in receivables
over the nine -month peri od ended March 31, 2012.  Please tell us how you determined that
your allowance for doubtful accounts was appropriate at March 31, 2012.  Include in your
response an aging of receivables at March 31, 2012 and a discussion of any amounts
collected subsequen t to the period end.   Describe any significant changes in your credit
policies or terms, if applicable.

Note 6 – Property, Plant, and Equipment, page 8

14. Please tell us why Buildings and Improvements decreased significantly and Machinery and
Equipment increased significantly from June 30, 2011 to March 30, 2012.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do no t foreclose
the Commission from taking any action with respect to the filing; and

Ken Ren
China Green Agriculture, Inc.
June 26, 2012
Page 5

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Amy Geddes at 202 -551-3304 or Margery Reich at 202 -551-3347  if
you have questions regarding comments on the financial statements and related matters.  Please
contact me at 202-551-3211  with any other questions.

Sincerely,

 /s/ David R. Humphrey

David R. Humphrey
Accounting Branch Chief