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Green Giant Inc.

6 Xinghan Road, 19th Floor

Hanzhong City, Shaanxi Province, PRC 723000

March 27, 2024

VIA EMAIL

Attn: William Demarest

Division of Corporation Finance

Office of Real Estate & Construction

    Re:
    Green Giant Inc.

    Form 10-K for Fiscal Year Ended September 30, 2023

    Filed December 28, 2023

    File No. 001-34864

Dear Mr. Demarest:

This letter is in response to the letter dated
March 20, 2024 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Green Giant Inc. (the “Company”, “we” or “our”). For ease of reference,
we have repeated the Commission’s comments in this response and numbered them accordingly.

Form 10-K for Fiscal Year Ended September 30,
2023

Consolidated Statements of Operations and Comprehensive
Loss, page F-5

 1. We note that for the year ended September 30, 2023, 51.1% of your revenues came from battery recycling.
However, no such revenues were earned for the period ended December 31, 2023 and disclosure in your 10-Q indicates that you are still
searching for a warehouse for your battery recycling production. On page 2 of the 10-K you disclose that in April 2023, you started the
trading of metals to leverage the fluctuation in their prices. Please clarify whether you have begun recycling from batteries or if revenues
recognized during the year ended September 30, 2023 are gains from trading in metals.

Response:
In response to the Staff’s comment, 51.1% and 0% of the revenues recognized for the year ended September 30, 2023 and the three
months ended December 31, 2023, respectively, were generated from the battery recycling business. Management had initially utilized a
small and temporary storage space to begin its battery recycling business for the fiscal year ended September 30, 2023 which was discontinued
for the period ended December 31, 2023 in search of a bigger and more efficient warehouse from a third party.

 2. We note your impairment of real estate property under development of $72.3 million and $73.6 million for
the years ended September 30, 2023 and 2022, respectively. Please explain to us in detail your basis for including this impairment line
as an operating expense for each of the years rather than as a component of cost of real estate sales to arrive at gross profit (loss).
In your response please clarify which real estate projects were impaired, the reason for impairment and cite the applicable accounting
guidance used in making your determination.

Response: In response to the Staff’s
comment, please see our response below:

Background

Currently,
Green Giant operates real estate development projects in Hanzhong, a prefecture-level city in Shaanxi Province, and Yang County, a county
in Hanzhong. The Company’s management has been focused on expanding its business in Tier 3 and Tier 4 cities and counties in China
that were strategically selected based on population and urbanization growth rates, general economic conditions and growth rates, income
and purchasing power of resident consumers, anticipated demand for private residential properties, availability of future land supply
and land prices, and governmental urban planning and development policies. The Company utilizes a standardized and scalable model that
emphasizes rapid asset turnover, efficient capital management and strict cost control. In addition to developing and constructing real
estate properties, the Company is required to build road infrastructures around the community of real estate properties to facilitate convenience
of living of residents in adjacent areas. The Company shall claim all or part of the building costs of these infrastructures from local
governments.

The Issue of Impairment Loss

The Company recorded fair value adjustment/impairment
loss of US$72.3 million and US$73.6 million for the fiscal years ended September 30, 2023 and 2022, respectively, as a result of the fair
value adjustment exercise. These adjustments reflect changes in the fair value of assets, such as account receivables from local government
held by the Company.

Quantitative Assessment of Impairment Test

Based on its historical experience in dealing
with local government authorities, the estimated collection rates for 5 years, 10 years, and 15 years from September 30, 2023, are 25%,
35%, and 40%, respectively. These estimates indicate the percentage of outstanding receivables that the Company anticipates it will actually
collect over those time periods from the local governments. The Company plans to revisit and potentially revise these estimates quarterly
to account for any changes in economic conditions or other factors that may affect receivable collections. Additionally, the company decided
to discount these estimated cash flows to their net present value (“NPV”) in order to reflect the time value of money. Any
difference between the receivables' nominal value and their NPV will be recorded as a fair value adjustment through profit and loss accounts.

The Company calculated an impairment loss in the
amount of RMB509,639,031 (US$72,255,403) for the year ended September 30, 2023 as shown in the table below:

    Total amount for fair value adjustment

    1,552,871,947
    10.80%

    Most costs accumulated 5 years before
    5 years from 9/30/2023
    10 years from 9/30/2023
    15 years from 9/30/2023
     Total impairment/

    Fair value adjustment
    as at 9/30/2023 Collection
    25%
    35%
    40%
     Fair value adjustment

    Completed projects as at 9/30/2023
    1,552,871,947
    388,217,987
    543,505,181
    621,148,779

    Company WACC at 10.8%

    232,475,318
    194,897,418
    133,382,616

    Total Impairment loss/fair value adjustment

    155,742,668
    348,607,764
    487,766,163
                         992,116,595

    Impairment loss in CNY as at 9/30/2022
                         482,477,564

    Impairment loss in US$ as at 9/30/2022
                           73,624,727

     Impairment loss in CNY as at 9/30/2023
                         509,639,031

     Impairment loss in US$ as at 9/30/2023
                           72,255,403

Total fair value adjustments as of the year ended
September 30, 2023 was calculated by subtracting RMB482,477,564 (US$73,624,727) as of the year ended September 30, 2023 from RMB992,116,595
(US$145,880,130) as of the year ended September 30, 2023, which equals RMB509,639,031 (US$72,255,403).

Key parameters and underlying assumptions include
but are not limited to:

 1. WACC (Weighted Average Cost of Capital): the Company’s WACC is quoted as 10.8%. This will be used
as the discount rate to calculate the net present value (NPV) of the cash flows from receivables. This is sourced from a financial portal
at www.findbox.com.

 2. Collection Rate of Receivables: The collection rates for receivables from local government authorities
over 5 years, 10 years, and 15 years from September 30, 2023, are estimated to be 25%, 35%, and 40%, respectively. These rates will be
used to estimate the cash flows expected to be received over those periods.

 3. Budget Cycle: The company observed the Chinese government’s five-year budget cycle plan. This implies
that significant changes or adjustments in receivables and other financial aspects might align with this cycle.

 4. No Bad Debt: The local government will fulfill its promise and pay in due course, the collectability of
the funds owed to the company becomes primarily a matter of the time value of money.

The impairment calculation for the year ended
September 30, 2022, was conducted similarly to that of September 30, 2023. The impairment loss or fair value adjustment for the year ended
September 30, 2022 amounted to RMB482,477,564 (US$73,624,727).

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General

 3. We issued comment letters on October 25, 2023 and on February 21, 2024 on the Form F-4 initially filed
by Green Giant Enterprise Inc. on October 3, 2023 and the preliminary proxy statements filed by Green Giant Inc. Please make the appropriate
corresponding changes in your future periodic reports for the comments issued on the Form F-4, as applicable.

Response: In response to the Staff’s
comment, we will make the appropriate corresponding changes in our future periodic reports for the comments issued on the Form F-4, as
applicable.

We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Joan Wu, Esq. of Hunter Taubman Fischer &
Li LLC, at (212) 530-2208.

    Sincerely,

    By:
    /s/ Yuhuai Luo

    Yuhuai Luo

    Chief Executive Officer

    Green Giant Inc.

    cc:
    Hunter Taubman Fischer & Li LLC

    Joan Wu, Esq. jwu@htflawyers.com

    Charles Tan, Esq. ctan@htflawyers.com

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