SecProbe.io

January 1 2, 2015

Ken Ren
Chief Financial Officer
 China Green Agriculture , Inc.
300 Walnut Street, Suite 245
Des Moines, Iowa 50309

Re: China Green Agriculture , Inc.
 Form 10-K for the Fiscal Year Ended June 30, 2014
Filed September 15, 201 4
File No. 001-34260

Dear Mr. Ren:

We have reviewed your filing  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 within ten business days 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 circumst ances , please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may have
additional comments.

Form 10 -K for the Fiscal Year Ended June 30, 2014

Risk Factors, page 25

Risks Related to Our Business, page 25

We have not obtained the land use right…., page 31

1. Please refer to your response to comment two in your response letter to the SEC Staff dated
July 19, 2012.  In this regard, you agreed to revise your disclosure concerning the dispu ted
land use right to discuss the progress of receiving the land use right, the probability you
might not receive it, the reasons why it may not be granted, and the financial exposure in
RMB and USD .  Please revise your disclosure accordingly and include d isclosure of any
current developments in this land use right.

Ken Ren
China Green Agriculture , Inc.
January 1 2, 2015
Page 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 49

Liquidity and Capital Resources, page 59

2. We note from your disclosure on page 61 that the significant increase in unearned revenue,
or customer deposits between June 30, 2013 and June 30, 2014 is largely attributable to the
advancement deposits  made by clients for the following purposes: 1) reservation and storage
for the coming plant season; a nd 2) locking up lower priced raw material in anticipation  of
price rise from this February .  In light of the fact that it appears that these customer deposits
also increased significantly in the quarter ended September 30, 2014, please explain to us,
and revise your MD&A section to disclose when you expect to recognize the revenue related
to these deposits.

Item 9A. Controls and Procedures, page 65
Management Report on Internal Control over Financial Reporting, page 65

3. We note from Management’s Report on Internal Control over Financial Reporting, that
management assessed your internal control over financial reporting as of the year ended
June 30, 2014 using the criteria set forth by the Committee of Sponsoring Organizations of
the Treadway Commission (C OSO) in the report entitled "Internal Control -Integrated
Framework. ”  Please tell us, and revise to disclose whether you used the 1992 or 2013
COSO framework in your assessment.

Financial Statements, page F -1

Report of Independent Registered Public Acc ounting Firm, page F -1

4. We note that the first paragraph of your independent auditors report indicates that the  audits
also included the financial statement schedule listed in the Index at Item 15(a) 2.   However,
it does not appear that this financial stat ement schedule has been included in your Form 10 -
K filing.  Please provide for us, and revise to disclose, the information included in this
financial statement schedule.

Notes to Consolidated Financial Statements, page F -6

Note 2 – Basis of Presentation and Summary of Significant Accounting Policies, page F -7

Accounts receivable, page F -7

5. It appears that your accounts receivable balance has significantly increased between June 30,
2012 and June 30, 2014, however your allowance for doubtful accounts has not increased in
similar proportion .  In this regard, the allowance for doubtful accounts has decreased  from
1% of accounts receivable at June 30, 2012,  to .2% of total accounts receivable at June 30,
2014.  Please explain to us why you believe your allowa nce for doubtful accounts is

Ken Ren
China Green Agriculture , Inc.
January 1 2, 2015
Page 3

 adequate as of June 30, 2014.  As part of your response, please provide us an accounts
receivable aging analysis as of June 30, 2013 and 2014.

Deferred assets, page F -8

6. We note that your balance of deferred assets has increas ed significantly in each of the last
two fiscal years.  We also note your disclosure that deferred assets represent amounts that
distributors owed to the company in their marketing efforts and developing standards stores
to expand the c ompany’s product com petitiveness and market shares, and such amount will
be expensed over three years, the term stated in the cooperation agreement.  We further note
from page F -11 that these marketing related assets were previously included in PP&E as of
June 30, 2013 but we re reclassified from property, plant and equipment to deferred assets
during 2014.  Given that you disclose that the amounts are owed to you from distributors,
but are a cash outflow in the statement of cash flows, the nature of this asset is unclear.
Please clearly explain to us the nature of the amounts paid to the distributors and tell us why
you believe the amounts are appropriately capitalized under ASC 340 -20.  Your response
should clearly explain your accounting, including why the deferred amounts r epresent an
asset and explain the reasons for the significant increase in recent years.  Also, please tell us
why you believe they are appropriately presented as an investing cash flow on the statement
of cash flows.  We may have further comment upon recei pt of your response.

Note 3 – Inventories, page F -12

7. We note your statement on page 13 that efficient production methods allow you to maintain
low inventory levels.  We further note from page 7 that large fertilizer inventory levels do
not guarantee profits.  In this regard, please tell us why your inventory  levels have increased
significantly from fiscal 2013 to fiscal 2014 and have continued to increase as of your
September 30, 2014 10 -Q.

Note 10  – Stock holders ’ Equity, page F -19

8. We note from your disclosure in Note 10 that over the last few years you have granted
shares of restricted stock to certain officers, directors and employees, which vest in various
installments.  Please revise your disclosure in Note 10 to include all disclosures required by
ASC 718 -10-50-2.

We urge all persons who are respo nsible 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.

Ken Ren
China Green Agriculture , Inc.
January 1 2, 2015
Page 4

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

 the co mpany 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 not foreclose the
Commission from taking any action with respect to the filing; and

 the company m ay 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 Heather Clark at 202 -551-3624 or Claire Erlanger at 202 -551-3301 if you
have ques tions regarding comments on the financial statements and related matters.  Please contact
me at 202 -551-3379 with any other questions.

Sincerely,

 /s/ Melissa Raminpour

Melissa Raminpour
Branch Chief