SecProbe.io

November 12, 2024
Yongcheng Yang
Chief Financial Officer
China Green Agriculture, Inc.
Third floor, Borough A, Block A. No. 181, South Taibai Road
Xi’an, Shaanxi Province, PRC 710065
Re:China Green Agriculture, Inc.
Form 10-K for the Fiscal Year Ended June 30, 2024
Filed October 15, 2024
File No. 001-34260
Dear Yongcheng Yang:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended June 30, 2024
Part I, Item 1. Business, page 1
1.Please revise Part I, Item 1, "Business" to include substantially similar disclosures to
your disclosures on pages 28 and 29 under the heading "Uncertainties with respect to
the PRC legal system, including uncertainties regarding the enforcement of laws, and
sudden or unexpected changes in policies, laws and regulations in China could
adversely affect us." In this regard, we note your responses to comments one and two
in your letter dated August 29, 2024, which undertook to update Part I, Item 1,
“Business” in future annual reports on Form 10-K to include this disclosure.
We note your response to comment 1. We also note the following disclosure included
in appendix E to your response letter dated October 1, 2024, which discussed loans
and payments between you, your subsidiaries and the VIE, and which is not included
in your annual report: "For the years ended June 30, 2022, 2023 and 2024, the CGA
provided loans of RMB277 million, RMB58.4 million and RMB62.3 million,
respectively, to Gufeng through Jinong, and received repayments of RMB50.2
million, RMB0.6 million and RMB1.6 million, respectively. For the years ended June 2.

November 12, 2024
Page 2
30, 2022, 2023 and 2024, CGA provided loans of RMB20.1 million, RMB5.3 million
and RMB10.1 million, respectively, to the VIE through Jinong, and received
repayments of RMB5.1 million, RMB1.8 million and RMB1 million, respectively."
Please tell us why this disclosure is not included in your discussion of cash flows on
page 4 of your annual report, and confirm that, in future filings, you will quantify any
cash flows and transfers of other assets by type that have occurred between the
holding company, its subsidiaries, and the consolidated VIEs, and direction of
transfer.
Part I, Item 1C. Cybersecurity., page 40
3.We note you do not include Item 1.C Cybersecurity. Please revise or advise us why
you do not provide the disclosure as applicable under Item 106 of Regulation S-K.
            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.
            Please contact Christie Wong at 202-551-3684 or Michael Fay at 202-551-3812 if you
have questions regarding comments on the financial statements and related matters. Please
contact Juan Grana at 202-551-6034 or Katherine Bagley at 202-551-2545 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:Robert Zepfel, Esq.