SecProbe.io

CORRESP
 1
 filename1.htm

 April
29, 2026

 VIA
EDGAR

 United
States Securities and Exchange Commission

 Division
of Corporate Finance

 Office
of Energy & Transportation

 100
F. Street, N.E.

 Washington,
D.C. 20549

 Attention:
Myra Moosariparambil and Kimberly Calder

 Re:

 Leishen
 Energy Holding Co., Ltd.

 Form
 20-F for Fiscal Year Ended September 30, 2025

 Filed
 January 30, 2026

 File
 No. 001-42445

 Dear
Staff,

 Leishen
Energy Holding Co., Ltd. (the " Company ," " we ," " our " or " us ")
hereby respectfully submits our response to the comment letter from the staff (the " Staff ") of the United States Securities
and Exchange Commission (the " Commission ") on April 16, 2026, relating to the above referenced Form 20-F for Fiscal
Year Ended September 30, 2025 (the " 20-F "). The Company is concurrently submitting an amended annual report on Form
20-F/A for the fiscal year ended September 30, 2025 (the " 20-F/A ").

 The
Staff's comments from its letter dated April 16, 2026 are repeated below in bold and followed by the Company's responses.
We have included page numbers to refer to the location in the 20-F where the language addressing the comments appears. Capitalized terms
used but not otherwise defined herein have the meanings set forth in the 20-F/A.

 Form
20-F for Fiscal Year Ended September 30, 2025

 Item
15. Controls and Procedures

 Management's
Annual Report on Internal Control over Financial Reporting and Attestation

 Report
of the Registered Public Accounting Firm, page 90

 1.
 As
 the company has previously filed an annual Form 20-F, it no longer meets the exemption requirements. Please amend the filing to provide
 management's annual report on internal control over financial reporting as required by Part II, Item 15(b) of the Form 20-F.
 Please ensure the amendment includes updated certifications that refer to the Form 20-F/A.

 Response :
We have revised the disclosure on pages 90 and 91 of the 20-F/A in response to the Staff's comment. In our revised disclosure,
we have included our management's annual report on internal control over financial reporting. Additionally, we have updated exhibits
12.1, 12.2, 13.1 and 13.2 to update management's certifications that refer to the Form 20-F/A.

 Index
to Consolidated Financial Statements

 Notes
to the Consolidated Financial Statements

 Note
20 – Segment Information, page F-31

 2.
 Please
amend your filing to provide the segment information required by Accounting Standard Update 2023-07 or explain why you believe you are
not subject to the amendments in the Update. To the extent you agree the Update is applicable in the current period, please provide all
disclosures required by ASC 280-10-50, including:

 ●
 The title and position of the individual or the name of
the group or committee identified as the chief operating decision maker. See ASC 280-10-50-21(c).

 ●
 Each segment's measure(s) of profit or loss used by
the chief operating decision maker (CODM) in assessing segment performance and allocating resources. See ASC 280-10-50-28A and 50-29.f.

 ●
 Disclosures that reconcile the segmented information with
consolidated financial information for each period an income statement is presented, as required by ASC 280-10-50-30 and 50-31.

 ●
 Significant expense categories that are regularly reviewed
by the CODM and included in reported segment profit or loss in accordance with ASC 280-10-50-26A. If you do not disclose significant
expense categories for one or more reportable segments, explain the nature of the expense information the CODM uses to manage operations.
See ASC 280-10-50-26C.

 ●
 Disclose amounts of other segment items that may be required
by ASC 280-10-50-26B, as applicable.

 Response :
We have revised the disclosure on pages F-31 and F-32 of the 20-F/A in response to the Staff's comment.

 We
thank the Staff for its review of the foregoing. If you have any questions regarding this matter, please do not hesitate to contact our
counsel, Huan Lou, Esq. at McCarter & English, LLP at hlou@mccarter.com or by telephone at 212-609-6836.

 Very
 truly yours,

 /s/
 Hongliang Li

 Hongliang
 Li

 Chief
 Executive Officer

 cc:
 Huan
 Lou, Esq.

 McCarter
 & English, LLP