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 Jin Medical International Ltd.

 No. 33 Lingxiang Road, Wujin District

 Changzhou City, Jiangsu Province

 People's Republic of China

 March 20, 2025

 Securities and Exchange Commission

 Division of Corporate Finance

 Office of Industrial Applications and Services

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Julie Sherman and Kristin Lochhead

 Re:
 Jin Medical International Ltd.

 Form 20-F for Fiscal Year Ended September 30, 2024

 Filed January 24, 2025

 File No. 001-41661

 Dear Ms. Julie Sherman and Ms. Kristin Lochhead

 Please find below our responses
to the questions raised by the staff (the "Staff") of the Securities and Exchange Commission (the "Commission")
in its letter of comments dated March 6, 2025 (the "Comment Letter") relating to the annual report on Form 20-F for Fiscal
Year Ended September 30, 2024, which was filed with the Commission by Jin Medical International Ltd. (the "Company" or "we")
on January 24, 2025 (the " Annual Report"). The Company is concurrently filing an amendment to the Annual Report herewith
(the "Amendment").

 For the Staff's convenience,
the Staff's comments have been stated below in their entirety in bold, followed by the corresponding responses from the Company.
Except for any page references appearing in the headings or the Staff's comments (which are references to Annual Report), all page
references herein correspond to the pages of the Amendment. Capitalized terms used but not defined in this letter have the meanings ascribed
to such terms in the Amendment and the Annual Report.

 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.

 Response: We have noted the Commission's
comments and will revise future filings to provide the specified information.

 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.

 Response: We have noted the Commission's
comments and will revise future filings to provide the specified information.

 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.

 Response: Please refer to the revised disclosures
at Item 15 of the Amendment.

 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.

 Response: The Company respectfully submits that
it will disclose the cost of related party revenue on the face of our consolidated statements of comprehensive income in compliance with
Rule 4-08(k) of Regulation S-X in future filings.

 Should you have any questions
regarding the foregoing, please do not hesitate to contact the Company's counsel, Huan Lou, Esq. of Sichenzia Ross Ference Carmel
LLP at (646) 810-2187.

 Very truly yours,
 For and on behalf of
 Jin Medical International Ltd.

 By:
 /s/ Erqi Wang

 Name:
 Erqi Wang

 Title:
 Chief Executive Officer