SecProbe.io

Mail Stop 3233
April 17, 2017

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 8 to Registration Statement on Form S-1
Filed March 27, 2017
  File No. 333-211051

Dear Mr. Xie :

We have reviewed your amended registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our March 13, 2017 letter .

General

1. We note your response to our prior comment 1 and your revised disclosure that “ Lansdale
Inc will intend to hold sufficient shares to become the parent of the Corporation.” We
further note your disclosure on page 6 that “Lansdale Inc is a holding company…” and
“After two years… Lansdale Inc will resale (sic) some shares of the Corpora tion… which
Lansdale Inc will be holding.” It appears that an investment decision has been made that
Lansdale will purchase  shares from you . Please tell us how this complies with Section 5
of the Securities Act.

Wanjun Xie, Chief Executive Officer
Achison Inc.
April 17, 2017
Page 2

2. We note your disclosure throughout the pro spectus that Lansdale is a holding company.
We further note your disclosure on page 6 where you indicate that you are setting up
several companies in the same industry, namely Landbay, Lemont, Linton and Dewriver.
Please revise your disclosure to clarify w hether you or Lansdale is the holding company
for these entities.

Prospectus Summary, page 6

3. We note your response to our prior comment 3 and your revised disclosure in paragraph 3
that you will not reimburse Blueville for expenses paid to date. Please reconcile this
disclosure with your disclosure on page 10 where you indicate that you will reimburse
Blueville for auditing and legal fees.

Exhibit 5. Legal Opinion

4. We note your response to our prior comment 4. The introductory language of paragraph 6
of the legal opinion continues to serve as an unacceptable qualification of the opinion in
paragraph 9, especially as it relates to parts (ii), (iii), and (iv) of paragraph 6.  Please ask
counsel to revise the introductory language or to delete parts (ii),  (iii), and (iv) of
paragraph 6. Refer to the Division of Corporation Finance’s Staff Legal Bulletin No. 19
for guidance.

Exhibit 23

5. Please include an updated consent from your independent accountant in the pre -effective
amendment.

You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilson Lee, Staff
Accountant,  at (202) 551 -3468 if you have questions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman  at (202) 551 -3585 or me at (202)
551-3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel
        Office of Real Estate and
Commodities