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November 15, 2023
Qiwei Miao
Chief Executive Officer
EShallGo Inc.
12F Block 16, No.1000 Jinhai Road
Pudong New District
Shanghai, China 201206
Re:EShallGo Inc.
Amendment No. 4 to Registration Statement on Form F-1
Filed October 20, 2023
File No. 333-271478
Dear Qiwei Miao:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our June 27, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1 Filed October 20, 2023
Selected Condensed Consolidated Statements of Cash Flows, page 13
1.The consolidated total net cash provided by (used in) operating activities and net cash
provided by financing activities for the year ended March 31, 2022 are inconsistent with
your consolidated statement of cash flows for 2022 presented on page F-7. Please revise to
reconcile the difference.
If the PRC government deems that the contractual arrangements. . ., page 40
2.We note your revisions to this risk factor and your removal of language indicating that
your PRC counsel states that there are substantial uncertainties regarding the interpretation
and application of current and future PRC Laws, regulations and rules. It is unclear why
you have revised this language when the opinion provided by counsel at Exhibit 99.1

 FirstName LastNameQiwei Miao
 Comapany NameEShallGo Inc.
 November 15, 2023 Page 2
 FirstName LastName
Qiwei Miao
EShallGo Inc.
November 15, 2023
Page 2
continues to express "substantial uncertainty." Please revise so that your disclosure is
consistent with the opinion provided.
PRC laws and regulations governing our current business operations. . ., page 48
3.We note the changes you made to your risk factor disclosures relating to legal and
operational risks associated with operating in China and PRC regulations. It is unclear to
us that there have been changes in the regulatory environment in the PRC since the review
of your last amendment filed on July 6, 2023 warranting revised disclosure to mitigate the
challenges you face and related disclosures. The Sample Letters to China-Based
Companies sought specific disclosure relating to uncertainties regarding the enforcement
of laws and that the rules and regulations in China can change quickly with little advance
notice. We do not believe that your revised disclosure referencing the PRC government’s
evolution of its regulatory oversight conveys the same risk. Please restore your disclosures
here and in all other places where you discuss the legal risks of operating in China to the
disclosures as they existed in the registration statement as of July 6, 2023.
Notes to Consolidated Financial Statements
Note 1 - Organization and Business Description
The VIE contractual arrangements, page F-11
4.Please reconcile the VIE net cash provided by (used in) operating activities and net cash
provided by financing activities for the year ended March 31, 2022 presented in the table
on page F-13 to your consolidated statement of cash flows for 2022 presented on page F-
7.
            Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you have
questions regarding comments on the financial statements and related matters. Please contact
Scott Anderegg at 202-551-3342 or Mara Ransom at 202-551-3264 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services