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 April 16, 2025

Jiaqi Hu
Chief Executive Officer
Julong Holding Ltd
Room 2009, Building A, Times Fortune World
No.1 Hangfeng Road, Fengtai District
Beijing, China 100070

 Re: Julong Holding Ltd
 Registration Statement on Form F-1
 Filed March 28, 2025
 File No. 333-286214
Dear Jiaqi Hu:

 We have reviewed your registration statement and have the following
comment(s).

 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.

Registration Statement on Form F-1 filed March 28, 2025
Report of Independent Registered Accounting Firm, page F-2

1. The report states financial statements as of and for the years ended
September 30,
 2024 and 2023 were audited. However, it refers only to "year" then ended
regarding
 the financial statements rather than "years" and the opinion sentence
does not refer to
 as of and for the year ended September 30, 2023. Please have your
auditor revise
 its report as appropriate. Refer to PCAOB AS 3101, paragraph 08. If
financial
 statements for either year were not audited and the opinion does not
cover fiscal year
 2023, please advise.
 April 16, 2025
Page 2

Notes to Combined and Consolidated Financial Statements
3. Recent accounting pronouncements, page F-14

2. We note you removed disclosure regarding recently issued accounting
 pronouncements not yet adopted, including ASU 2023-07, Improvements to
 Reportable Segment Disclosures and ASU 2023-09, Improvements to Income
Tax
 Disclosures. Please explain why the disclosures were removed or revise
to include the
 disclosures required by ASC 250-10-S99-5 (SAB Topic 11:M). If you
adopted ASU
 2023-07 for the year ending September 30, 2024 as you previously
disclosed you
 expected to do, tell us how your disclosure complies with this standard.
Condensed Financial Statements of Julong Holding LImited, page F-24

3. Please clarify if these financial statements are those of the parent
company. Also, it is
 not clear if these financial statements are included in the notes to the
audited
 combined and consolidated financial statements or provided as a schedule
to the filing
 in association with the information regarding Schedule I that follows
these statements.
 In either case, these financial statements are to be audited the same as
the audited
 combined and consolidated financial statements (including related notes)
referred to in
 the independent auditor's report. If these financial statements are
included as an
 audited schedule to the filing, the independent auditor's report needs
to refer to this
 schedule. Refer to Item 8.A of Form 20-F, Rule 5-04(c) of Regulation S-X
and
 PCAOB AS 3101. Please revise as appropriate.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Scott Stringer at 202-551-3272 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Rucha Pandit at 202-551-6022 or Lilyanna Peyser at 202-551-3222 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Yang Ge
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