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October 13, 2023
Suqin Li
Chief Executive Officer
Majestic Ideal Holdings Ltd
22/F, China United Plaza
1002-1008, Tai Nan West Street
Cheung Sha Wan, Kowloon, Hong Kong
Re:Majestic Ideal Holdings Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed September 18, 2023
File No. 333-271502
Dear Suqin Li:
            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.
Amendment No. 2 to Registration Statement on Form F-1 filed September 18, 2023
General
1.We note the changes you made to your disclosure appearing on the cover page, Summary
and Risk Factor sections, 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 amendment that was filed on May 16, 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 the
risk that the PRC government may intervene in or influence your operations at any time,
or may exert control over operations of your business, which could result in a material
change in your operations and/or the value of the securities you are registering for sale.
We remind you that, pursuant to federal securities rules, the term “control” (including the
terms “controlling,” “controlled by,” and “under common control with”) as defined in

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 13, 2023 Page 2
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 13, 2023
Page 2
Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or
cause the direction of the management and policies of a person, whether through the
ownership of voting securities, by contract, or otherwise.” The Sample Letters also sought
specific disclosures 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 intent to
strengthen its regulatory oversight conveys the same risk. Please restore your disclosures
in these areas to the disclosures as they existed in the amendment that was filed on May
16, 2023.
Dilution, page 44
2.Please tell us how your $(10,719,688) and $(0.09) net tangible book value and net tangible
book value per share were calculated.
September 30, 2022 Annual Financial Statements
Consolidated Statements of Income and Comprehensive Income, page F-4
3.Your note at the bottom of page F-4 indicates that your basic and diluted earnings per
share were retroactively adjusted for the July 2023 stock split, however, we note no
change to the earnings per share amount for each period presented.  Please revise to
include the correct amounts for earnings per share using the weighted average number of
ordinary shares after the stock split of 18 million.
Consolidated Statements of Changes of Shareholders' (Deficit) Equity, page F-5
4.It appears as the No. of Shares column has not been retroactively adjusted for the July
2023 stock split.  Please revise.  Your March 31, 2023 interim shareholders' equity
statement should be similarly revised.
March 31, 2023 Interim Financial Statements
Unaudited Condensed Statements of Income and Comprehensive Income, page F-28
5.Your calculation of earnings (loss) per share appears to be calculated using
comprehensive income rather than net income.  Please revise both your interim and annual
statements of income to calculate earnings per share using net income.
Notes to the Consolidated Financial Statements
10. Leases, page F-44
6.Please clarify your statement that the outstanding operating leases are below your
threshold for capitalization and therefore, "no right of use assets and liabilities were
recognized under ASU 842" given that in the table above, you have right of use assets and
liabilities recorded on the balance sheet.

 FirstName LastNameSuqin Li
 Comapany NameMajestic Ideal Holdings Ltd
 October 13, 2023 Page 3
 FirstName LastName
Suqin Li
Majestic Ideal Holdings Ltd
October 13, 2023
Page 3
12. Taxes
China, page F-46
7.Please clarify why you have a provision for income taxes in your income statement
of RMB 677,656 with a net loss and negative tax rate of (105.9)%.  Your response should
address the nature of the large adjustments to your effective tax rates including the tax loss
not recognized of (30.6)% and tax concession of (97.6)%.
            Please contact Heather Clark at 202-551-3624 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence S. Venick, Esq.