SecProbe.io

CORRESP
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    Graubard
                                            Miller

    The
    Chrysler Building

    405
    Lexington Avenue

    New
    York, N.Y. 10174-4499

    (212)
    818-8800

    (212)
    818-8881

    (212)
    818-8638

    email
    address

    jgallant@graubard.com

May
19, 2023

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Bowen
                                            Acquisition Corp

Draft
Registration Statement on Form S-1

Submitted
April 17, 2023

    CIK
    No.: 0001973056

Ladies
and Gentlemen:

On
behalf of Bowen Acquisition Corp (“Company”), we respond as follows to the Staff’s comment letter, May 10, 2023, relating
to the above-captioned Draft Registration Statement on Form S-1 (“Registration Statement”). Captions and page references
herein correspond to those set forth in the amended Registration Statement, a copy of which has been marked with the changes from the
original draft submission of the Registration Statement.

Please
note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s response
to each comment immediately thereafter.

Form
DRS Submitted April 17, 2023

Cover
Page

 1. Please
                                            disclose whether and how the Holding Foreign Companies Accountable Act, as amended by the
                                            Consolidated Appropriations Act, 2023, and related regulations will affect your company.
                                            Your prospectus summary should address, but not necessarily be limited to, the risks highlighted
                                            on the prospectus cover page.

We
have revised the cover page and prospectus summary on page 9 of the Registration Statement as requested.

Securities
and Exchange Commission

May
19, 2023

Page
2

 2. Please
                                            clarify that the public shareholders will not have the opportunity to vote if the board extends
                                            the period of time to consummate the business combination for up to 18 months.

We
have revised the cover page of the prospectus included in the Registration Statement as requested.

 3. Please
                                            clarify on page iii whether your sponsors are located in China. We note your disclosure on
                                            page 117 that Na Gai is the sole director and shareholder of Createcharm Holdings Ltd.

We
have revised the disclosure on page iii as requested to indicate that neither of the Company’s sponsors are domiciled in China.
As indicated on page 1 of the Registration Statement, Createcharm Holdings Ltd is a British Virgin Islands company and Bowen Holding
LP is a Delaware limited partnership.

Risk
Factors, page 29

 4. Please
                                            include a risk factor that describes the potential material effect on your shareholders of
                                            the stock buyback excise tax enacted as part of the Inflation Reduction Act in August 2022.
                                            If applicable, include in your disclosure that the excise tax could reduce the trust account
                                            funds available to pay redemptions or that are available to the combined company following
                                            a de-SPAC. Describe the risks of the excise tax applying to redemptions in connection with:

 ● liquidations
                                            that are not implemented to fall within the meaning of “complete liquidation”
                                            in Section 331 of the Internal Revenue Code;

 ● extensions,
                                            depending on the timing of the extension relative to the when the SPAC completes a de-SPAC
                                            or liquidates, and

 ● de-SPACs,
                                            depending on the structure of the de-SPAC transaction.

Also
describe, if applicable, the risk that if existing SPAC investors elect to redeem their shares such that their redemptions would subject
the SPAC to the stock buyback excise tax, the remaining shareholders that did not elect to redeem may economically bear the impact of
the excise tax.

We
have revised the disclosure on page 31 of the Registration Statement as requested.

*
* * * * * * * * *

Securities
and Exchange Commission

May
19, 2023

Page
3

If
you have any questions, please do not hesitate to contact me at the above telephone and facsimile numbers.

    Sincerely,

    /s/
    Jeffrey M. Gallant

    Jeffrey
    M. Gallant

    cc:
    Jiangang
    Luo