SecProbe.io

CORRESP
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May 19, 2022

Via Edgar

Mr. Jay Ingram

Ms. Jennifer Angelini

Ms. Melissa Gilmore

Mr. Martin James

Office of Technology

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E

Washington, DC 20549

Re: Kandi Technologies
Group, Inc.

Form 10-K for the Year
Ended December 31, 2021

Filed March 15, 2022

File No. 001-33997

Ladies and Gentlemen:

This letter is being furnished
in response to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange
Commission (the “Commission”) that were contained in the Staff’s letter dated April 7, 2022 (the “Comment Letter”),
to Kandi Technologies Group, Inc. (the “Company” or “Kandi”) with respect to the Form 10-K for the Year Ended
December 31, 2021 (the “10-K”).

This letter provides the Company’s
responses to the Staff’s comments contained in the Comment Letter. The text of the Staff’s comments is set forth in bold below,
followed by the responses of the Company.

Form 10-K for the Year Ended December 31,
2021

Part I, page 1

 1. We note your disclosure on page 8 that Kandi New Energy was a VIE prior to March
14, 2022. Accordingly, please revise your definitions on page 1 to 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, disclose, if true, that your subsidiaries and/or the VIE conduct operations
in China, that the VIE is consolidated for accounting purposes but is not an entity in which you owned equity prior to March 14, 2022,
that these contracts have not been tested in court, and that the holding company does not conduct operations. Disclose clearly the entity
(including the domicile) in which investors are purchasing an interest. Define the term “PRC operating entities” that is used
starting on page 11.

Response: In response to the
Staff’s comment, the Company has revised its disclosure throughout the proposed Amendment No. 1 on Form 10-K/A (the “Form
10-K/A”) herein attached as Exhibit A. As previously discussed and agreed by our counsel and the Staff, we will file the Form 10-K/A
publicly once all the comments are cleared by the Staff. In addition, the Company has also revised and added the definition of “PRC
operating entities” on page 1of the Form 10-K/A.

Item 1

Business Introduction, page 2

 2. We note your disclosure that you are a Delaware holding company with operations
conducted by your subsidiaries based in China. Please additionally disclose that you are not a Chinese operating company and that this
structure involves unique risks to investors. Provide a cross-reference to you detailed discussion of risks facing the company as a result
of this structure.

Response: In response to the
Staff’s comment, the Company has revised the Our Core Business under Item 1 on page 2 of the Form 10-K/A.

 3. We note your prominent disclosure about the legal and operational risks associated
with being based in or having the majority of the company’s operations in China on page 2. Please revise your disclosure to make
clear whether these risks could result in a material change in the value of your securities or cause the value of your securities to significantly
decline or be worthless. Your risk factors section should address, but not necessarily be limited to, the risks highlighted in this section.

Response: In response to the
Staff’s comment, the Company points the Staff to page 2 of the Form 10-K/A, and notes that clear disclosure regarding whether these
risks could result in a material change in the value of our securities or cause the value of our securities to significantly decline or
be worthless has already been provided. In addition, the Company has included other identical disclosures on pages 2, 16, and 22 of the
Form 10-K/A, at the end of the paragraph.

 4. Disclose each permission or approval that you or your subsidiaries are required to obtain from Chinese
authorities to operate your business and to offer securities to foreign investors. State whether you or your subsidiaries are covered
by permissions requirements from the China Securities Regulatory Commission, Cyberspace Administration of China (CAC), or any other governmental
agency that is required to approve your or your subsidiaries’ 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 or your subsidiaries: (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 response to the
Staff’s comment, the Company has revised and added the required disclosure on page 13 of the Form 10-K/A in Our Core Business under
Item 1. In addition, the Company has also added the required disclosure on page 12 of the Form 10-K/A under Item 1 regarding permissions
or approvals that the Company or our subsidiaries are required to obtain from Chinese authorities to operate our business and to offer
securities to foreign investors.

 5. Provide a clear description of how cash is transferred through your organization.
Disclose your intentions to distribute earnings or settle amounts owed under applicable agreements. State whether any transfers, dividends,
or distributions have been made to date between the holding company, its subsidiaries, and consolidated VIEs, or to investors, and quantify
the amounts where applicable. 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 has 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, to the parent company and U.S. investors as well as the ability to settle amounts owed under applicable agreements. Provide
cross-references to the condensed consolidating schedule and the consolidated financial statements.

Response: In response to the
Staff’s comment, the Company has revised and added the requested disclosure on page F-10 of the Form 10-K/A under Note 1. The Company
points the Staff to page 27 and 29 under the Risk Factors of the Form 10-K/A, and notes that clear disclosure regarding restrictions
on foreign exchange and our ability and intention to distribute earnings to U.S. investors has already been provided. The Company has
also added the requested disclosure regarding how cash is transferred through our organization on pages 9 and 10 of the Form 10-K/A under
Item 1.

 6. Please disclose whether your auditor is subject to the determinations announced
by the PCAOB on December 16, 2021, and whether and how the Holding Foreign Companies Accountable Act (HFCAA) and related regulations will
affect your company. Disclose that trading in your securities may be prohibited under the HFCAA if the PCAOB determines that it cannot
inspect or investigate completely your auditor, and that as a result an exchange may determine to delist your securities.

Response: In response to the
Staff’s comment, the Company has revised and added the required disclosure on pages 13 and 14 of the Form 10-K/A in Our Core Business
under Item 1, and on page 26 of the Form 10-K/A under Risk Factors.

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 7. We note your response to our prior comments 2 and 3. Please further revise your
disclosure to address the following:

 ● Clearly state, if true, that you have not yet produced and sold your K23 and
K27 electric vehicles (other than the low-speed “neighborhood” version) in any markets.

 ● Update the disclosure that you expect to make the first U.S. deliveries of the
UTV K32 in the late first quarter of 2022, since the quarter has now ended. Disclose whether the UTV K32 has been or will be sold in markets
other than the United States and the expected obstacles and timetable.

 ● Clarify your “home market” for purposes of discussing imports and exports,
taking into account that the registrant is a U.S. entity. For example, the following sentence is difficult to understand and should be
revised for clarity: “There are two major sales modes of our export products: the first mode is indirect sales to domestic import
and export companies for external sales, and the second is direct sales to foreign importers.”

 ● Correct the reference to the year 2028 on page 4.

Response to bullet point 1:
In response to the Staff’s comment, the Company points out that the Company does not sell the complete set of K23 and K27 vehicles
(other than the low-speed “neighborhood” version) in any market. The K23 produced by the Company are sold to its business partners
with vehicle production qualifications in the form of electric vehicle components, and the business partners would further assemble and
adjust those K23 before the sales in the PRC market.

Response to bullet point 2:
In response to the Staff’s comment, the Company points out that as of March 2022, we have shipped 20 pieces of UTV K32 to the
United States for our subsidiary SC Autosports to kick off the sales at the U.S. market. In addition, for now the Company wants to focus
on the U.S. Market, but will probably expand to other markets after obtaining sustainable market shares in U.S.

Response to bullet point 3: In
response to the Staff’s comment, the Company has revised and added the required disclosure on pages 5, 16, and 28 of the Form 10-K/A.

Response to bullet point 4: In
response to the Staff’s comment, the Company has corrected the reference to the year 2018 on page 4 of the Form 10-K/A.

 8. We note several recent developments, including (i) Zhejiang Kandi Technologies’ agreement to acquire
100% of Jiangxi Huiyi, (ii) the joint venture between Kandi Hainan and Jiangsu Xingchi to establish Hainan Kandi Holding New Energy Technology,
and (iii) the framework agreement with Hunan Hengrun Automobile to jointly produce battery-swappable electric vehicles. Please describe
the material terms of these agreements in your business section and file these agreements as exhibits to the Form 10-K.

Response: In response to the
Staff’s comment, the Company points out to the Staff that regarding (i), the Company has filed the agreements with Zhejiang Kandi
Technology to acquire 100% equity of Jiangxi Huiyi as exhibits in its Current Report of 8-K filed on July 19, 2021. Regarding (ii), the
investment in joint venture between Kandi Hainan and Jiangsu Xingchi to establish Hainan Kandi Holding New Energy Technology is only 0.6%
of the Company’s total assets as of December 31, 2021. Therefore, the Company does not consider that as a material contract. Regarding
(iii), since it is only a framework agreement without any material transactions taking place yet, the Company does not consider it as
a material contract.

Item 1

Business Introduction

Selected Condensed Consolidated Financial
Schedule, page 8

 9. Please revise your schedules to directly reflect the intercompany activities and balances related to
the VIE Agreement(s) in your consolidating schedules and present intercompany activities, balances for receivables and payables, and cash
flows in separate lines for each entity. Additionally, footnote significant activities within the schedules to assist investors in understanding
the relationships and transactions from your historical contractual arrangement(s).

Response: In response to the
Staff’s comment, the Company has added the requested disclosure regarding the intercompany activities, present intercompany activities,
balances for receivables and payables, and cash flows in separate lines for each entity on pages 10 and 11 of the Form 10-K/A under Item
1.

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Item 1A

Risk Factors, page 11

 10. 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 risk factors section. 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 your securities. 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 such securities to significantly decline or be worthless.

Response: In response to the
Staff’s comment, the Company points the Staff to the Risk Factors of the Form 10-K/A, and notes that clear disclosure regarding
risks mentioned in Comment 10 has already been provided. In addition, the Company has revised and added the requested disclosure on page
16 of the Form 10-K/A under Risk Factors Summary.

 11. We note your disclosure about the HFCAA. Please expand your risk factors to disclose
that the United States Senate has passed the Accelerating Holding Foreign Companies Accountable Act, which, if enacted, would decrease
the number of “non-inspection years” from three years to two years, and thus, would reduce the time before your securities may
be prohibited from trading or delisted. Update your disclosure to reflect that the Commission adopted rules to implement the HFCAA and
that, pursuant to the HFCAA, the PCAOB has issued its report notifying the Commission of its determination that it is unable to inspect
or investigate completely accounting firms headquartered in mainland China or Hong Kong.

Response: In response to the
Staff’s comment, the Company has revised and added the requested disclosure on page 26 of the Form 10-K/A under Risk Factors.

 12. In light of recent events indicating greater oversight by the CAC over data
security, particularly for companies seeking to list on a foreign exchange, please revise your disclosure on pages 19-20 to explain how
this oversight impacts your business and your ability to offer securities to investors and to what extent you believe that you are compliant
with the regulations or policies that have been issued by the CAC to date.

Response: In response to the
Staff’s comment, the Company has revised and added requested disclosure on page 24 of the Form 10-K/A under Risk Factors.

Item 2

Properties, page 27

 13. Please revise your disclosure to clearly describe the status
of your Haikou City factory,