SecProbe.io

March 6, 2025
Ziqiang Wang
Chief Financial Officer
Jin Medical International Ltd.
No. 33 Lingxiang Road, Wujin District
Changzhou City, Jiangsu Province
People’s Republic of China
Re:Jin Medical International Ltd.
20-F for Fiscal Year Ended September 30, 2024
Filed January 24, 2025
File No. 001-41661
Dear Ziqiang Wang:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended September 30, 2024
Item 5. Operating and Financial Review and Prospects
A. Operating Results, Comparison of Results of Operations for the Fiscal Years Ended
September 30, 2024 and 2023, page 87
1.We see that revenue from wheelchair products decreased 9% from FY24 to FY23
while revenue from wheelchair components increased 149%. We also note from page
55 and 61 that the percentage of revenue derived from Nissin, the sole distributor in
Japan, decreased from 70% of revenue in FY23 to 48% in FY24. Revise future filings
to provide greater clarity about the underlying reasons for the fluctuations in revenue
from period to period, including how changes in the geographic distribution of
revenue and sales to major customers impacted revenue and whether that trend is
expected to continue in the future. In addition, when you include multiple reasons for
fluctuations, such as for wheelchair product revenue, future filings should quantify the
impact of each item.

March 6, 2025
Page 2
B. Liquidity and Capital Resources, page 96
2.We note significant changes in your liquidity and capital resources such as
increases in cash, short-term investments and accounts receivable along with increases
in bank loans. However, we do not see any discussion about the underlying reasons
for these trends. Revise future filings to include more robust discussion about any
known trends or any known demands, commitments, events or uncertainties that will
result in or that are reasonably likely to result in the registrant's liquidity increasing or
decreasing in any material way. In addition, future filing should more fully describe
any known material trends, favorable or unfavorable, in the registrant's capital
resources. Reference Item 303(b)(1) of Regulation S-K.

Item 15. Controls and Procedures
Managements Annual Report on Internal Control over Financial Reporting, page 137
3.You disclose that you have identified a significant weakness in your internal control
over financial reporting; however it does not appear that you have included
management's report of internal control over financial reporting that complies with
Item 308 of Regulation S-K. Please amend your filing to disclose management’s
report on the effectiveness of your internal controls over financial reporting, including
an explicit statement as to whether or not internal control over financial reporting is
effective. Refer to the requirements of Item 308(a) of Regulation S-K. You may
provide an abbreviated amendment that includes a cover page, explanatory note, the
complete text of Item 15, a signature page and the certification required by Item
601(b)(31) of Regulation S-K, including paragraphs 1,2,4 and 5. Please ensure the
revised certifications refer to the appropriate amendment and are currently dated.

Please also revise to remove the disclosure that the Annual Report does not include a
report of management’s assessment regarding internal control over financial reporting
due to a transition period established by rules of the SEC for newly listed public
companies. Since this is your second Form 20-F, the transition period is no longer
applicable to you.

Consolidated Statement of Comprehensive Income, page F-5
4.Please tell us why you do not disclose the cost of related party revenue on the face of
your consolidated statement of comprehensive income in compliance with Rule 4-
08(k) of Regulation S-X.

March 6, 2025
Page 3
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Julie Sherman at 202-551-3640 or Kristin Lochhead at 202-551-3664
with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services