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    Unassociated Document

      CHINA
GREEN AGRICULTURE, INC.

      3rd
Floor, Borough A, Block A. No.181, South Taibai Road, Xi’an, Shaanxi Province,
People’s Republic of China 710065

    August 3,
2010

    Division
of Corporation Finance

    Securities
and Exchange Commission

    100 F
Street, NE

    Mail
Stop: 3561

    Washington,
D.C. 20549

    Attention:  Juan
Migone

                Re:

                China
      Green Agriculture, Inc.

                  Form
      10-K for the fiscal year ended June 30, 2009

                  File
      No.: 001-34260

    Dear Mr.
Migone:

    China
Green Agriculture, Inc., a Nevada corporation (the “Company”), is in receipt of
the verbal comments (the “Comments”) of the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”)  provided to
Elizabeth F. Chen, Esq., securities counsel to the Company, during a telephone
conference on July 21, 2010 regarding the Company’s response letter to the
Commission dated June 18, 2010 on the subject matter (the “June 18
Letter”).  We hereby submit this letter in response to the
Comments.  The Comments are paraphrased in italics below, followed by
the responses of the Company.

    Form 10-K for the Fiscal
Year Ended June 30, 2009

    Notes to Consolidated
Financial Statements

    Note 14 – Income Taxes, page
F-17

              1.

              Please clarify that the
      company, taken as a whole, is not completely tax free. As a result, please
      revise the last sentence in Footnote 14 to the Company’s Consolidated
      Financial Statements, which states that “Due to non-operation in U.S. and
      tax free status in China, the Company had no deferred tax for the fiscal
      year ended June 30, 2009 and 2008.” In that sentence, the reference to
      “tax free status in China” is
inaccurate.

    Response:

    We agree that the reference to “tax
free status in China”  in footnote 14 (“Footnote 14”) to our
Consolidated Financial Statements included in our Annual Report on Form 10-K for
the fiscal year ended June 30, 2009 (the “Form 10-K”) is inaccurate and we have
revised Footnote 14 accordingly. We also replaced the reconciliation table
included therein with a more comprehensive one to reflect the breakdowns at each
operating subsidiary’s level.  Please refer to the revised Footnote 14
set forth on Appendix A attached hereto.

        1

        CHINA
GREEN AGRICULTURE, INC.

        3rd
Floor, Borough A, Block A. No.181, South Taibai Road, Xi’an, Shaanxi Province,
People’s Republic of China 710065

              2.

              Please clarify that the
      company has nominal deferred tax, instead of stating the Company does not
      have or record any deferred
tax.

    Response:

    We had nominal deferred tax on a gross
basis for the fiscal years ended June 30, 2009 and 2008; however, we did not
have any deferred tax on a net basis in those periods. We have clarified this in
our revised Footnote 14 set forth on Appendix A attached hereto.

      ***

    We acknowledge that we are responsible
for the adequacy and accuracy of the disclosure in the Form 10-K.  We
further acknowledge that Staff comments or changes to disclosure in response to
Staff comments in the Form 10-K do not foreclose the Commission from taking any
action with respect to the Form 10-K, and that we 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.

            Sincerely,

              /s/
      Ken Ren

              Ken
      Ren

              Chief
      Financial Officer

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        Appendix
A to the response letter to the Commission dated August 3,
2010

      NOTE
14 - INCOME TAXES

      The
Company utilizes SFAS No. 109, "Accounting for Income Taxes," which requires the
recognition of deferred tax assets and liabilities for the expected future tax
consequences of events that have been included in the financial statements or
tax returns. Under this method, deferred income taxes are recognized for the tax
consequences in future years of differences between the tax bases of assets and
liabilities and their financial reporting amounts at each period end based on
enacted tax laws and statutory tax rates applicable to the periods in which the
differences are expected to affect taxable income. Valuation allowances are
established, when necessary, to reduce deferred tax assets to the amount
expected to be realized.

       The
provision for income taxes as of June 30, 2009 and 2008 consisted of the
following:

                2009

                2008

                Current
      income tax - Provision for China income and local tax

                $

                2,331,548

                $

                692,474

                Deferred
      taxes

                -

                -

                Total
      provision for income taxes

                $

                2,331,548

                $

                692,474

      Beginning
January 1, 2008, in the People's Republic of China (PRC) the new Enterprise
Income Tax (“EIT”) law replaced the then existing laws for Domestic Enterprises
(“DES”) and Foreign Invested Enterprises (“FIEs”). The new standard EIT rate of
25% replaced the 33% rate then applicable to both DES and FIEs. The two year tax
exemption and three year 50% tax reduction tax holiday for production-oriented
FIEs was eliminated. Since January 1, 2008, TechTeam Jinong became subject to
income tax in China at a rate of 15%, as a result of the expiration of its tax
exemption on December 31, 2007, it made provision for income taxes as of June
30, 2009 and 2008 of $2,331,548 and $692,474, respectively, which is mainly due
to the operating income from TechTeam Jinong. Xi’an Jintai was exempt from
paying income tax for calendar 2008 as it produces the products which fall into
the tax exemption list issued by the government.

          1

      Appendix A to the response letter to the Commission dated August
3, 2010

      The
following table reconciles the U.S. statutory rates to the Company’s effective
tax rate as of June 30, 2009 and 2008:

                    FY 2008

                    China

                    15%

                    United States

                    34%

                    Total

                    Pretax income
      (loss)

                  10,717,921

                  (2,246,920

                  )

                  8,471,001

                    Expected incom tax expense
      (benefit)

                  1,607,688

                  15.00

                  %

                  (763,953

                  )

                  34.00

                  %

                    Nontaxable income on
      Jintai

                  (296,230

                  )

                  -2.76

                  %

                    Nontaxable income on
      Jinong

                  (618,984

                  )

                  -5.78

                  %

                  Change in valuation allowance on
      deferred tax asset

                       from US tax
      benefit

                  763,953

                  -34.00

                  %

                    Actual tax
      expense

                  692,474

                  6.46

                  %

                  0

                  0.00

                  %

                  8.17

                  %

                    FY 2009

                    China

                    15%

                    United States

                    34%

                    Total

                    Pretax income
      (loss)

                  18,188,877

                  (1,392,907

                  )

                  16,795,970

                    Expected incom tax expense
      (benefit)

                  2,728,332

                  15.00

                  %

                  (473,588

                  )

                  34.00

                  %

                    Nontaxable income on
      Jintai

                  (366,936

                  )

                  -2.02

                  %

                    Nontaxable income on
      Jinong

                  (29,848

                  )

                  -0.16

                  %

                  Change in valuation allowance on
      deferred tax asset

                       from US tax
      benefit

                  473,588

                  -34.00

                  %

                    Actual tax
      expense

                  2,331,548

                  12.82

                  %

                  0

                  0.00

                  %

                  13.88

                  %

      Although
the Company did not have any operating income in the U.S. for the fiscal years
of 2009 and 2008, it incurred various expenses in the U.S. including but not
limited to stock exchange application and listing fees, registration fees of the
Commission, legal and investor relations fees, professional fees payable to
qualified tax consultants and auditors and compensation expenses to the
Company’s officers and independent directors. Accordingly, the Company’s U.S.
operations have deferred taxes in the form of net operating losses (“NOLs”).
However due to the uncertainty that some or all of the deferred tax assets will
not be realized in the coming years, the Company recorded a full valuation
allowance against its nominal deferred tax assets and thus had no deferred tax
on a net basis for the fiscal year ended June 30, 2009 and 2008,
respectively.

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