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CHINA GREEN AGRICULTURE, INC.

Third floor,
Borough A, Block A. No. 181, South Taibai Road, Xi’an, Shaanxi Province, PRC 710065

August 29, 2024

Via Edgar

Securities and Exchange Commission

Division of Corporation Finance

Office of Industrial Applications and Services

100 F Street, NE

Washington, D.C. 20549

Attention: Juan Grana

    Re:
     China Green Agriculture, Inc.

Form 10-K for the Fiscal Year Ended June 30, 2023

Filed December 15, 2023

File No. 001-34260

Dear Mr. Grana:

China Green Agriculture, Inc.,
a Nevada corporation (the “Company” or “we”), is in receipt of the letters from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) dated March 27, 2024 and May 6, 2024 (the “Comment Letters”)
to the Company, aw well as the telephonic comments received May 29, 2024, with respect to the Company’s Annual Report on Form 10-K
for the year ended June 30, 2023, and Amendment No. 1 thereto (the “Form 10-K”).

We hereby file via EDGAR our
response to the Comment Letters. The text of the Staff’s comment is set forth in italics below, followed by the response of the Company.

Part I, Item 1. Business, page 1

1. We note your response to comment 1 and your proposed
disclosure in Appendix A. In future filings, please also revise at the onset of Part I to disclose prominently that you are not a
Chinese operating company but a Nevada holding company with operations conducted by your subsidiaries and through contractual
arrangements with variable interest entities (VIEs) based in China and that this structure involves unique risks to investors. If
true, disclose that these contracts have not been tested in court. Explain whether the VIE structure is used to provide investors
with exposure to foreign investment in China-based companies where Chinese law prohibits direct foreign investment in the operating
companies, and disclose that investors may never hold equity interests in the Chinese operating company. Your disclosure should
acknowledge that Chinese regulatory authorities could disallow this structure, which would likely result in a material change in
your operations and/or a material change in the value of your securities, including that it could cause the value of your securities
to significantly decline or become worthless. Provide a cross-reference to your detailed discussion of risks facing the company as a
result of this structure.

RESPONSE:

The Company undertakes to update Part I, Item 1, “Business”
in future Annual Reports on Form 10-K to include the disclosure as shown in Appendix A at the beginning.

2. We note your response to comment 1 and your proposed disclosure
in Appendix A. In future filings, please revise to also clarify whether these risks could result in a material change in your operations
and/or the value of your securities or could significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.

RESPONSE: The Company will include additional disclosure
in the “Business” section, as shown on Appendix A, to the effect that the risks described therein could result in a material
change in our operations and the value of our Common Stock, and that these factors could hinder our ability to offer or continue to offer
securities to investors and cause the value of such securities to significantly decline or be worthless.

3. We note that your auditor, GAO CPA Firm, is based in Frisco, TX.
In future filings, please revise your disclosure in this section to disclose the location of your auditor’s headquarters and whether
and how the Holding Foreign Companies Accountable Act, as amended by the Consolidated Appropriations Act, 2023, and related regulations
will affect your company.\

RESPONSE: In future filings, the Company undertakes to
add the following paragraph under the caption Business-- Risks Related to Doing Business in the PRC:”

Although the majority of our operations in China, our outside
auditors, GAO CPA Firm, are located in the United States, at 14648 Falling Leaf Drive, Frisco, TX 75035. The Holding Foreign Companies
Accountable Act requires the SEC to identify public companies that have retained a registered public accounting firm to issue an audit
report where the firm has a branch or office that: (1) is located in a foreign jurisdiction, and (2) the Public Company Accounting Oversight
Board (“PCAOB”) has determined that it is unable to inspect or investigate completely because of a position taken by an authority
in the foreign jurisdiction. Since our auditors are located in Texas, and we are not owned or controlled by the Chinese government,
we do not believe that the Holding Foreign Companies Accountable Act is applicable to us.

4. We note the diagram of the company’s corporate structure provided
on page 3. In future filings, please revise to describe all contracts and arrangements through which you claim to have economic rights
and exercise control that results in consolidation of the VIE’s operations and financial results into your financial statements.
Identify clearly the entity in which investors are purchasing their interest and the entity(ies) in which the company’s operations
are conducted. Describe the relevant contractual agreements between the entities and how this type of corporate structure may affect
investors and the value of their investment, including how and why the contractual arrangements may be less effective than direct ownership
and that the company may incur substantial costs to enforce the terms of the arrangements. Disclose the uncertainties regarding the status
of the rights of the holding company with respect to its contractual arrangements with the VIE, its founders and owners, and the challenges
the company may face enforcing these contractual agreements due to legal uncertainties and jurisdictional limits. Please also revise
the structure chart on page 3 to remove the solid line with an arrow pointing from Jinong to the VIE company, and replace this with a
dashed line and arrow, in order to avoid any suggestion that Jinong controls the VIE company.

RESPONSE:

In future filings the Company will include the paragraph
set forth on Appendix B immediately after the table on page 3. In addition, the Company will remove the solid line with an arrow pointing
from Jinong to the VIE company in the chart, and replace this with a dashed line and arrow.

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5. In future filings, please clearly disclose how you will refer
to the holding company, subsidiaries, and VIEs when providing the disclosure throughout the document so that it is clear to
investors which entity the disclosure is referencing and which subsidiaries or entities are conducting the business operations.
Refrain from using terms such as “we” or “our” when describing activities or functions of a VIE. For
example, we note your disclosure on page 1 which refers to Yuxing as “one of Jinong’s VIEs” as well as your references on
pages 2, 30 and 43 to “our VIEs” or “our VIE.”

RESPONSE:

In future filings the Company will refrain from implying
that it owns the VIE.

6. We note that neither the investors in the holding company nor
the holding company itself have an equity ownership in, direct foreign investment in, or control of, through such ownership or
investment, the VIE. Accordingly, in future filings, please refrain from implying that the contractual agreements are equivalent to
equity ownership in the business of the VIE. Any references to control or benefits that accrue to you because of the VIE should be
limited to a clear description of the conditions you have satisfied for consolidation of the VIE under U.S. GAAP. Additionally, your
disclosure should clarify that you are the primary beneficiary of the VIE for accounting purposes. Please also disclose, if true,
that the VIE agreements have not been tested in a court of law. We also note your disclosure on page 1 that states you operate
through variable interest entities, Yuxing and Tianjuyuan. However, we note your disclosure in the structure chart on page 3 that
shows Jinong as your wholly-owned PRC subsidiary which contracts with the VIE company (Yuxing), and Gufeng as another one of your
wholly-owned PRC subsidiaries with Tianjuyuan as its wholly-owned subsidiary. We also note your disclosure on page 2 that Gufeng and
Tianjuyuan are wholly-owned subsidiaries of Jinong and indirect subsidiaries of the company. Please revise to reconcile these
disclosures and clarify which entities are VIEs or wholly-owned subsidiaries.

RESPONSE:

Th first paragraph of Appendix B, to be included in
future filings, clarifies that neither the Company nor its subsidiary owns equity interests in the VIE, that these contractual
relationships are not equivalent to equity, that their purpose is to allow the Company to consolidate their results for US GAAP
purposes, and that these contracts have not been tested in a court of law. Also, the paragraph under “Our History” has
been corrected to indicate that Tianjuyuan is a subsidiary of Gufeng not Jinong, and that Yuxing is the only VIE. Finally, the chart
on page 3 will be revised to conform to this disclosure, and will add in the VIE.

    3

7. In future filings, please disclose each permission or approval
that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate your business and to offer
securities to foreign investors. State whether you, your subsidiaries, or VIEs are covered by permissions requirements from the
China Securities Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is
required to approve the VIE’s operations, and state affirmatively whether you have received all requisite permissions or
approvals and whether any permissions or approvals have been denied. Please also describe the consequences to you and your investors
if you, your subsidiaries, or the VIEs: (i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude
that such permissions or approvals are not required, or (iii) applicable laws, regulations, or interpretations change and you are
required to obtain such permissions or approvals in the future.

RESPONSE:

In future filings, we will add the disclosure set forth
on Appendix D into the 10-K under “Government Regulation,” relating to cybersecurity regulation.

8. In future filings, please provide a clear description of how
cash is transferred through your organization. Disclose your intentions to distribute earnings or settle amounts owed under the VIE
agreements. 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. Quantify any dividends or distributions that a subsidiary or
consolidated VIE have made to the holding company and which entity made such transfer, and their tax consequences. Similarly
quantify dividends or distributions made to U.S. investors, the source, and their tax consequences. Your disclosure should make
clear if no transfers, dividends, or distributions have been made to date. Describe any restrictions on foreign exchange and your
ability to transfer cash between entities, across borders, and to U.S. investors. Describe any restrictions and limitations on your
ability to distribute earnings from the company, including your subsidiaries and/or the consolidated VIEs, to the parent company and
U.S. investors as well as the ability to settle amounts owed under the VIE agreements.

RESPONSE:

In future filings, we will add the disclosure set forth
on Appendix E in the 10-K under “Business”.

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9. In future filings, please revise to include a summary of risk
factors. In your summary of risk factors, disclose the risks that your corporate structure and being based in or having the majority
of the company’s operations in China poses to investors. In particular, describe the significant regulatory, liquidity, and
enforcement risks with cross-references to the more detailed discussion of these risks in the document. For example, specifically
discuss risks arising from the legal system in China, including risks and uncertainties regarding the enforcement of laws and that
rules and regulations in China can change quickly with little advance notice; and the risk that the Chinese government may intervene
or influence your operations at any time, or may exert more control over offerings conducted overseas and/or foreign investment in
China-based issuers, which could result in a material change in your operations and/or the value of the securities you are
registering for sale. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over
offerings that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or completely
hinder your ability to offer or continue to offer securities to investors and cause the value of your securities to significantly
decline or be worthless.

RESPONSE:

In future filings, we will include a “Summary of
Risk Factors” at the beginning of the “Risk Factors” section, as set forth on Appendix F

Item 1A. Risk Factors., page 20

10. Revise your risk factors in future filings to acknowledge that
if the PRC government determines that the contractual arrangements constituting part of the VIE structure do not comply with PRC regulations,
or if these regulations change or are interpreted differently in the future, your securities may decline in value or become worthless
if the determinations, changes, or interpretations result in your inability to assert contractual control over the assets of your PRC
subsidiaries or the VIEs that conduct all or substantially all of your operations.

RESPONSE: In future filings, we will add the following
paragraph under “Risk Factors-- Risks Related to Doing Business in the PRC:

Risks Relating to Contractual Arrangements with the
VIE

It is possible that the government of the PRC might determine
that the contractual arrangements underlying the VIE structure are not in compliance with PRC laws, regulations, or interpretations either
in their current form or if these laws or regulations change or are interpreted differently in the future. If such determinations, changes,
or interpretations result in our inability to assert contractual control over the assets of our PRC subsidiaries or the VIE that conduct
all or substantially all of our operations, our Common Stock could become worthless.”

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11. We note your risk factor disclosure on page 32 of your annual
report discussing the PRC government’s significant influence over companies with China-based operations. Given the Chinese
government’s significant oversight and discretion over the conduct and operations of your business, please revise your risk
factor disclosure in future filings to describe any material impact that intervention, influence, or control by the Chinese
government has or may have on your business or on the value of your securities. Highlight separately the risk that the Chinese
government may intervene or influence your operations at any time, which could result in a material change in your operations and/or
the value of your securities. Also, given recent statements by the Chinese government indicating an intent to exert more oversight
and control over offerings that are conducted overseas and/or foreign investment in China-based issuers, acknowledge the risk that
any such action could significantly limit or completely hinder your ability to offer or continue to offer securities to investors
and cause the value of such securities to significantly decline or be worthless. We remind you that, pursuant to federal securities
rules, the term “control” (including the terms “controlling,” “controlled by,” and “under