SecProbe.io

CORRESP
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 Greenland Technologies Holding Corporation

 March 31, 2026

 Via EDGAR

 Division of Corporation Finance

 Office of Technology

 U.S. Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C., 20549

 Attention:
 Mr. Edwin Kim

 Re:
 Greenland Technologies Holding Corporation

 Registration Statement on Form S-3

 Filed on March 27, 2026

 File No. 333-294700

 Ladies and Gentlemen:

 In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Greenland Technologies Holding Corporation hereby
requests that the effectiveness of the above-referenced Registration Statement on Form S-3 be accelerated to, and that the Registration
Statement become effective at, 9:00 a.m., Eastern Time, on April 2, 2026, or as soon thereafter as practicable.

 Very truly yours,

 Greenland Technologies Holding Corporation

 By:
 /s/ Raymond Wang

 Name:
 Raymond Wang

 Title:
 Chief Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 30, 2026

Raymond Wang
Chief Executive Officer
Greenland Technologies Holding Corp.
50 Millstone Road, Building 400 Suite 130
East Windsor, NJ 08512

 Re: Greenland Technologies Holding Corp.
 Registration Statement on Form S-3
 Filed March 27, 2026
 File No. 333-294700
Dear Raymond Wang:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Edwin Kim at 202-551-3297 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Ying Li, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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GREENLAND TECHNOLOGIES HOLDING CORPORATION

50 Millstone Road, Building 400 Suite 130

East Windsor, NJ 08512

United States

VIA EDGAR

June 4, 2021

Ms. Alexandra Barone

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C., 20549

 Re: Greenland Technologies Holding Corporation

Registration Statement on Form S-3 (File
No. 333-256509)

Request for Acceleration of Effectiveness

Dear Ms. Barone:

In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, Greenland Technologies Holding Corporation hereby
requests that the effectiveness of the above-referenced Registration Statement on Form S-3 be accelerated to, and that the Registration
Statement become effective at, 4:30p.m., Eastern Time, on June 7, 2021, or as soon thereafter as practicable.

    Very truly yours,

    Greenland Technologies Holding Corporation

    By:
    /s/ Raymond Z. Wang

    Name:
    Raymond Z. Wang

    Title:
    Chief Executive Officer

United States securities and exchange commission logo
June 3, 2021
Jing Jin
Chief Executive Officer
Greenland Technologies Holding Corporation
50 Millstone Road, Building 400 Suite 130
East Windsor, NJ 08512
Re:Greenland Technologies Holding Corporation
Registration Statement on Form S-3
Filed May 26, 2021
File No. 333-256509
Dear Mr. Jin:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rule 461 regarding requests for acceleration.  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.
            Please contact Alexandra Barone, Staff Attorney, at (202) 551-8816 or Jan Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Ying Li

CORRESP
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May 11, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Attn: Matthew Crispino

    Re:
    Greenland Technologies Holding Corporation

        Registration Statement on Form S-3,
        originally filed on March 20, 2020

    File No. 333-237321 (the “Registration Statement”)

Request for Acceleration

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules
and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Greenland Technologies
Holding Corporation hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it
will become effective at 4:00 pm, Eastern Time, on May 12, 2020, or as soon thereafter as practicable.

Please note that we acknowledge the following:

● should the Securities and Exchange Commission
(the “Commission”) or the staff (the “Staff”), acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the filing;

● the action of the Commission or the Staff,
acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and

● the Company may not assert Staff comments
and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

    Very truly yours,

    Greenland Technologies Holding Corporation

    By:
    /s/ Raymond Z. Wang

    Name:

        Title:

    Raymond
    Z. Wang
Chief Executive Officer

September 27, 2019
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza, No. 1 East
Chang'an Street
Dongcheng District
Beijing, People's Republic of China
Re:Greenland Acquisition Corporation
Preliminary Proxy Statement on Schedule 14A
Filed July 12, 2019
File No. 1-38605
Dear Mr. Liu:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
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Greenland Acquisition Corporation

Suite 906, Tower W1, Oriental Plaza

No. 1 East Chang’an Street, Dongcheng
District

Beijing, China 100006

September 10, 2019

VIA EDGAR

Division of Corporation Finance

Office of Manufacturing and Construction

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549-4561

Attn: Edward M. Kelly

    Re:
    Greenland Acquisition Corporation

        Revised Preliminary Proxy Statement
        on Schedule 14A

        Filed August 21, 2019

        File No. 001-38605

Dear Mr. Kelly:

Greenland Acquisition
Corporation, a British Virgin Islands company (the “Company”, “we”, “us” or “our”),
hereby transmits its responses to the comment letter received from the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) on September 3, 2019, regarding the Revised Preliminary Proxy Statement on Schedule
14A filed with the Commission on August 21, 2019 (the “Proxy Statement”).

For the Staff’s
convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s
response. Disclosure changes made in response to the Staff’s comments have been made in Amendment No. 2 to the Proxy Statement
on Schedule 14A (the “Amended Proxy Statement”), which is being filed with the Commission contemporaneously with the
submission of this letter.

Revised Preliminary Proxy Statement
on Schedule 14A filed August 21, 2019

Financial Statements of Zhongchai
Holding (Hong Kong) Limited for the Period Ended June 30, 2019

Note 7 - Property, Plant and Equipment,
page F-53

    1.
    Please revise your presentation to ensure the total amounts of property, plant and equipment, net are properly displayed within the table on page F-53.

In response to the
Staff’s comment, we have revised our disclosure on page F-53 of the Amended Proxy Statement.

Financial Statements of Zhongchai
Holding (Hong Kong) Limited for the Year Ended December 31, 2018

Note 25 - Subsequent Events, page
F-91

    2.
    We have reviewed your response to prior comment 18. We note that you have now disclosed the actual date through which subsequent events have been evaluated. Please revise your disclosure here and on page F-60 to disclose also whether the date through which subsequent events have been evaluated is the date the financial statements were issued or the date the financial statements were available to be issued. Refer to ASC 855-10-50-1.

In response to the
Staff’s comment, we have revised our disclosure on pages F-60 and F-91 of the Amended Proxy Statement to clarify that subsequent
events have been evaluated through the date the financial statement were issued.

We thank the Staff
in advance for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel,
Ari Edelman, of Ellenoff Grossman & Schole LLP, at aedelman@egsllp.com or by telephone at (212) 370-1300.

    Very truly yours,

    /s/ Yanming Liu

    Yanming Liu, Chief Executive Officer

    Greenland Acquisition Corporation

    cc:
    Ellenoff Grossman & Schole LLP

    T&C Law Firm

September 3, 2019
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza, No. 1 East
Chang'an Street
Dongcheng District
Beijing, People's Republic of China
Re:Greenland Acquisition Corporation
Revised Preliminary Proxy Statement on Schedule 14A
Filed August 21, 2019
File No. 1-38605
Dear Mr. Liu:
            We have reviewed your filing and have the following comments.  In some of our
comments we may ask you to provide us information so that we may better understand your
disclosure.
            Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe that
our comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Revised Preliminary Proxy Statement on Schedule 14A filed August 21, 2019
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Period Ended June 30,
2019
Note 7 - Property, Plant and Equipment, page F-53
1.Please revise your presentation to ensure the total amounts of property, plant and
equipment, net are properly displayed within the table on page F-53.
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Year Ended December
31, 2018
Note 25 - Subsequent Events, page F-91
2.We have reviewed your response to prior comment 18.  We note that you have now

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corporation
 September 3, 2019 Page 2
 FirstName LastName
Yanming Liu
Greenland Acquisition Corporation
September 3, 2019
Page 2
disclosed the actual date through which subsequent events have been evaluated.  Please
revise your disclosure here and on page F-60 to disclose also whether the date through
which subsequent events have been evaluated is the date the financial statements were
issued or the date the financial statements were available to be issued.  Refer to ASC 855-
10-50-1.
            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.
            You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866 or W. John
Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions regarding comments on
the financial statements and related matters.  Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Jay E. Ingram, Legal Branch Chief, at (202) 551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
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Greenland
Acquisition Corporation

Suite
906, Tower W1, Oriental Plaza

No.
1 East Chang’an Street, Dongcheng District

Beijing,
China 100006

August 21, 2019

VIA
EDGAR

Division
of Corporation Finance

Office
of Manufacturing and Construction

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549-4561

Attn:
Edward M. Kelly

 Re: Greenland
Acquisition Corporation

    Preliminary
Proxy Statement on Schedule 14A

Filed
July 12, 2019

File
No. 1-38605

Dear
Mr. Kelly:

Greenland
Acquisition Corporation, a British Virgin Islands company (the “Company”, “we”, “us” or “our”),
hereby transmits its responses to the comment letter received from the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) on August 6, 2019, regarding the Preliminary Proxy Statement on Schedule
14A filed with the Commission on July 12, 2019 (the “Proxy Statement”).

For the Staff’s
convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s
response. Disclosure changes made in response to the Staff’s comments have been made in Amendment No. 1 to the Proxy Statement
on Schedule 14A (the “Amended Proxy Statement”), which is being filed with the Commission contemporaneously with the
submission of this letter.

Preliminary
Proxy Statement on Schedule 14A filed July 12, 2019

Selected
Historical Consolidated Financial and Other Data of Zhongchai Holding, page 20

 1. We
                                         note that gross profit for the years ended December 31, 2018 and 2017 as presented on
                                         page 20 does not agree to the amounts presented on page F-39. Please revise your presentation
                                         to reconcile this apparent discrepancy.

In response to the
Staff’s comment, we have revised our disclosure on page 20 of the Amended Proxy Statement.

Selected
Unaudited Pro Forma Condensed Combined Financial Information, page 21

 2. Please
                                         ensure that the amounts presented here agree to the amounts presented in your pro forma
                                         financial statements beginning on page 98. In this regard, you present on page 23 cash
                                         and cash equivalents on a combined pro forma basis, assuming no redemptions, in the amount
                                         of $46,450,791 as of February 28, 2019; however, the related amount as presented on page
                                         100 is $45,670,042.

We acknowledge the
Staff’s comment. Please note that we have revised and updated our disclosure as of May 31, 2019 on pages 23 and 102 of the
Amended Proxy Statement.

As
Zhongchai Holding expands its operations, it may need to establish a more diverse supplier network..., page 34

 3. Indicate
                                         here whether you have any agreement with any of your key suppliers, and, if so, disclose
                                         the material terms of any agreement with any of your key suppliers in the business section.

In response to the
Staff’s comment, we have revised our disclosure on pages 34 and 142 of the Amended Proxy Statement.

The
Share Exchange Agreement, page 59

 4. Notwithstanding
                                         the disclaimers here and in the last paragraph under “Representations and Warranties”
                                         on page 63, the representations, warranties, and covenants in the merger agreement filed
                                         as Annex A with the proxy statement constitute public disclosure for purposes of the
                                         federal securities laws, and you are responsible for considering whether additional specific
                                         disclosures of material information about material contractual provisions of the merger
                                         agreement are required to make the statements in the proxy statement not misleading.
                                         Please include disclosure acknowledging that if specific material facts exist that contradict
                                         the representations, warranties, and covenants in the merger agreement, you have provided
                                         corrective disclosure in the proxy statement. Furthermore, if subsequent information
                                         concerning the subject matter of the representations, warranties, and covenants in the
                                         merger agreement may or may not be fully reflected in your public disclosures, please
                                         clarify that your public disclosures will include any material information necessary
                                         to provide Greenland’s shareholders a materially complete understanding of the
                                         merger agreement disclosures.

In response to the
Staff’s comment, we have revised our disclosure on page 59 of the Amended Proxy Statement.

Description
of negotiation process with Zhongchai Holding, page 72

 5. Disclosure
                                         in the third paragraph states that Greenland and Zhongchai Holding conducted a meeting
                                         on November 18, 2018 and that Mr. David Ming He and Mr. Hanyi Zhou had a detailed discussion
                                         about Zhongchai Holding’s current and forecasted financial results. Please summarize
                                         the forecasted financial results discussed.

In response to the
Staff’s comment, we have revised the disclosure on pages 72, 78 and 79 of the Amended Proxy Statement.

    2

Greenland
Board’s Reasons for the Approval of the Business Combination, page 75

 6. Under
                                         “Other Terms and Conditions of the Share Exchange Agreement,” please disclose
                                         the existing board member of Zhongchai Holding, one of the existing board members of
                                         Greenland, and the three director nominees who will serve as members of the Greenland
                                         board of directors post-closing.

In response to the
Staff’s comment, we have revised the disclosure on page 76 of the Amended Proxy Statement.

 7. In
                                         the fifth bullet point statement on page 77, please elaborate on the risks associated
                                         with the transportation industry in general.

In response to the
Staff’s comment, we have revised the disclosure on page 77 of the Amended Proxy Statement.

Suppliers,
page 138

 8. Disclosure
                                         indicates that Zhongchai Holding purchases raw materials from a small number of suppliers.
                                         Please disclose Zhongchai Holding’s key suppliers.

In response to the
Staff’s comment, we have revised our disclosure on pages 34 and 142 of the Amended Proxy Statement.

Management’s
Discussion and Analysis of Financial Condition and Results of Operations of Zhongchai Holding Results of Operations, page 146

 9. We
                                         note your risk factor on page 40 related to the value of the Renminbi against the U.S.
                                         dollar and its effect on your financial results reported in U.S. dollar terms. Please
                                         fully expand your discussion of each component of your results of operations for each
                                         period presented to appropriately address the impact of foreign currencies on your reported
                                         results from period to period.

In response to the
Staff’s comment, we have added disclosure on the impact of foreign currency to our results of operation on page 152 of the
Amended Proxy Statement.

 10. You
                                         disclose on page 148 that other income decreased by $0.08 million due to the decrease
                                         of interest income. We note that other income is presented separately from interest income
                                         on page F-39. As such, please enhance your disclosure to clarify the types of items included
                                         within other income. Please also discuss the reasons for the changes in the interest
                                         income and interest expense line items.

In response to the Staff’s comment,
we have revised our disclosure on page 155 of the Amended Proxy Statement.

Contractual
Obligations, page 151

 11. Please
                                         revise your table of contractual obligations to include in a separate line item the estimated
                                         interest payments on your debt. Because the table is aimed at increasing transparency
                                         of cash flow, we believe that these payments should be included in the table. Please
                                         also disclose any assumptions you made to derive these amounts.

In response to the
Staff’s comment, we have revised our disclosure on page 159 of the Amended Proxy Statement.

    3

New
Financial Accounting Pronouncements, page 152

 12. We
                                         note that you do not think the adoption of certain pronouncements, such as ASU 2014-09
                                         and ASU 2015-17, will have a material impact on your financial position, results of operations,
                                         cash flows, or disclosures. Since these pronouncements are effective for you, please
                                         revise your disclosure to clearly state that you adopted the pronouncements and they
                                         did not have an impact on your financial position, results of operations, or cash flows,
                                         if true. In this regard, we note your disclosure on pages F-50 and F-51 whereby you did
                                         definitively disclose your conclusions of the impact of adoption of pronouncements that
                                         are already effective for you.

In response to the
Staff’s comment, we have revised our disclosure on pages 160 and 161 of the Amended Proxy Statement.

Financial
Statements of Greenland Acquisition Corporation for the Year Ended November 30, 2018, page F-1

 13. Please
                                         include interim financial statements for the period ended May 31, 2019. Please similarly
                                         update your financial information throughout the filing. See Rule 8-08 of Regulation
                                         S-X.

In
response to the Staff’s comment, we have included the interim financial statements for the period ended May 31, 2019 and
have updated our financial information throughout the filing.

Note
7. Commitments and Contingencies

Registration
Rights, page F-30

 14. We
                                         note that you entered into registration rights agreements on July 24, 2018 and on July
                                         12, 2019 as disclosed on pages F-30 and 67. Please disclose whether there are any maximum
                                         cash penalties under the registration rights agreements, if applicable. Please also disclose
                                         any additional penalties resulting from delays in registering your common stock. Refer
                                         to ASC 825-20-50-1.

In response to the Staff’s comment, we have revised our disclosure on pages F-14 and F-31 to indicate
that no cash penalties are payable under the registration rights agreement.

Financial
Statements of Zhongchai Holding (Hong Kong) Limited for the Year Ended December 31, 2018, page F-34

 15. Please
                                         include interim financial statements for the period ended June 30, 2019. Please similarly
                                         update your financial information throughout the filing. See Rule 8-08 of Regulation
                                         S-X.

In response to the Staff’s
comment, we have included the interim financial statements for the period ended June 30, 2019 and have updated our financial information
throughout the filing.

    4

Consolidated
Statements of Cash Flows, page F-42

 16. Please
                                         help us understand why you have presented interest paid within the cash flows from financing
                                         activities section. In this regard, we remind you that net income (loss) reported on
                                         your cash flows statements already accounts for interest expense during each respective
                                         period.

In response to the
Staff’s comment, we have revised our disclosure on pages F-67 and F-68 of the Amended Proxy Statement. We respectfully advise
the Staff that in the revised “Consolidated Statements of Cash Flows,” we have reallocated the numbers under items
“interest expense” and “interest paid” to items “other current liabilities,” “due to
related parties and “other long-term liabilities.”

Note
2. Summary of Significant Accounting Policies

Cost
of Goods Sold, page F-45

 17. Please
                                         revise your disclosure to indicate if you include depreciation or amortization in your
                                         cost of goods sold. If you do not include depreciation or amortization in your cost of
                                         goods sold, please revise your presentation to comply with SAB Topic 11:B, which would
                                         include revising the cost of goods sold title and removing the gross profit subtotal
                                         throughout the filing. See SAB Topic 11:B.

In response to the
Staff’s comment, we have revised our disclosure on page F-71 of the Amended Proxy Statement.

Note
25. Subsequent Events, page F-64

 18. Please
                                         disclose the actual date through which subsequent events have been evaluated. Refer to
                                         ASC 855-10-50-1.

In response to the
Staff’s comment, we have revised our disclosure on page F-91 of the Amended Proxy Statement.

General

 19. Please
                                         include a form of proxy which is marked clearly to indicate that it is preliminary. See
                                         Rule 14a-6(e)(1) of Regulation 14A.

In response to the
Staff’s comment, we have included a form of proxy at the end of the Amended Proxy Statement and have clearly marked that
such proxy is preliminary.

We
thank the Staff in advance for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact
our legal counsel, Ari Edelman, of Ellenoff Grossman & Schole LLP, at aedelman@egsllp.com or by telephone at (212) 370-1300.

    Very
    truly yours,

    /s/
    Yanming Liu

    Yanming
    Liu, Chief Executive Officer

    Greenland
    Acquisition Corporation

    cc:
    Ellenoff Grossman & Schole LLP

    T&C Law Firm

5

August 6, 2019
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza, No. 1 East
Chang'an Street
Dongcheng District
Beijing, People's Republic of China
Re:Greenland Acquisition Corporation
Preliminary Proxy Statement on Schedule 14A
Filed July 12, 2019
File No. 1-38605
Dear Mr. Liu:
            We have reviewed your filing and have the following comments.  In some of our
comments we may ask you to provide us information so that we may better understand your
disclosure.
            Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response and any amendment you may file in response to these
comments, we may have additional comments.
Preliminary Proxy Statement on Schedule 14A filed July 12, 2019
Selected Historical Consolidated Financial and Other Data of Zhongchai Holding, page 20
1.We note that gross profit for the years ended December 31, 2018 and 2017 as presented on
page 20 does not agree to the amounts presented on page F-39.  Please revise your
presentation to reconcile this apparent discrepancy.

Selected Unaudited Pro Forma Condensed Combined Financial Information, page 21
2.Please ensure that the amounts presented here agree to the amounts presented in your pro
forma financial statements beginning on page 98.  In this regard, you present on page 23
cash and cash equivalents on a combined pro forma basis, assuming no redemptions, in

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corporation
 August 6, 2019 Page 2
 FirstName LastNameYanming Liu
Greenland Acquisition Corporation
August 6, 2019
Page 2
the amount of $46,450,791 as of February 28, 2019; however, the related amount as
presented on page 100 is $45,670,042.
As Zhongehai Holding expands its operations, it may need to establish a more diverse supplier
network..., page 34
3.Indicate here whether you have any agreement with any of your key suppliers, and, if so,
disclose the material terms of any agreement with any of your key suppliers in the
business section.
The Share Exchange Agreement, page 59
4.Notwithstanding the disclaimers here and in the last paragraph under "Representations and
Warranties" on page 63, the representations, warranties, and covenants in the merger
agreement filed as Annex A with the proxy statement constitute public disclosure for
purposes of the federal securities laws, and you are responsible for considering whether
additional specific disclosures of material information about material contractual
provisions of the merger agreement are required to make the statements in the proxy
statement not misleading.  Please include disclosure acknowledging that if specific
material facts exist that contradict the representations, warranties, and covenants in the
merger agreement, you have provided corrective disclosure in the proxy statement.
Furthermore, if subsequent information concerning the subject matter of the
representations, warranties, and covenants in the merger agreement may or may not be
fully reflected in your public disclosures, please clarify that your public disclosures will
include any material information necessary to provide Greenland's shareholders a
materially complete understanding of the merger agreement disclosures.
Description of negotiation process with Zhongchai Holding, page 72
5.Disclosure in the third paragraph states that Greenland and Zhongchai Holding conducted
a meeting on November 18, 2018 and that Mr. David Ming He and Mr. Hanyi Zhou had a
detailed discussion about Zhongchai Holding's current and forecasted financial results.
Please summarize the forecasted financial results discussed.
Greenland Board's Reasons for the Approval of the Business Combination, page 75
6.Under "Other Terms and Conditions of the Share Exchange Agreement," please disclose
the existing board member of Zhongchai Holding, one of the existing board members of
Greenland, and the three director nominees who will serve as members of the Greenland
board of directors post-closing.
7.In the fifth bullet point statement on page 77, please elaborate on the risks associated with
the transportation industry in general.
Suppliers, page 138

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corporation
 August 6, 2019 Page 3
 FirstName LastNameYanming Liu
Greenland Acquisition Corporation
August 6, 2019
Page 3
8.Disclosure indicates that Zhongchai Holding purchases raw materials from a small
number of suppliers.  Please disclose Zhongchai Holding's key suppliers.
Management’s Discussion and Analysis of Financial Condition and Results of Operations of
Zhongchai Holding
Results of Operations, page 146
9.We note your risk factor on page 40 related to the value of the Renminbi against the U.S.
dollar and its effect on your financial results reported in U.S. dollar terms.  Please fully
expand your discussion of each component of your results of operations for each period
presented to appropriately address the impact of foreign currencies on your reported
results from period to period.
10.You disclose on page 148 that other income decreased by $0.08 million due to the
decrease of interest income.  We note that other income is presented separately from
interest income on page F-39.  As such, please enhance your disclosure to clarify the types
of items included within other income.  Please also discuss the reasons for the changes in
the interest income and interest expense line items.
Contractual Obligations, page 151
11.Please revise your table of contractual obligations to include in a separate line item the
estimated interest payments on your debt.  Because the table is aimed at increasing
transparency of cash flow, we believe that these payments should be included in the table.
Please also disclose any assumptions you made to derive these amounts.
New Financial Accounting Pronouncements, page 152
12.We note that you do not think the adoption of certain pronouncements, such as ASU
2014-09 and ASU 2015-17, will have a material impact on your financial position, results
of operations, cash flows, or disclosures.  Since these pronouncements are effective for
you, please revise your disclosure to clearly state that you adopted the pronouncements
and they did not have an impact on your financial position, results of operations, or cash
flows, if true.  In this regard, we note your disclosure on pages F-50 and F-51 whereby
you did definitively disclose your conclusions of the impact of adoption of
pronouncements that are already effective for you.
Financial Statements of Greenland Acquisition Corporation for the Year Ended November 30,
2018, page F-1
13.Please include interim financial statements for the period ended May 31, 2019.  Please
similarly update your financial information throughout the filing.  See Rule 8-08 of
Regulation S-X.
Note 7. Commitments and Contingencies
Registration Rights, page F-30

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corporation
 August 6, 2019 Page 4
 FirstName LastNameYanming Liu
Greenland Acquisition Corporation
August 6, 2019
Page 4
14.We note that you entered into registration rights agreements on July 24, 2018 and on July
12, 2019 as disclosed on pages F-30 and 67.  Please disclose whether there are any
maximum cash penalties under the registration rights agreements, if applicable.  Please
also disclose any additional penalties resulting from delays in registering your common
stock.  Refer to ASC 825-20-50-1.
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Year Ended December
31, 2018, page F-34
15.Please include interim financial statements for the period ended June 30, 2019.  Please
similarly update your financial information throughout the filing.  See Rule 8-08 of
Regulation S-X.
Consolidated Statements of Cash Flows, page F-42
16.Please help us understand why you have presented interest paid within the cash flows
from financing activities section.  In this regard, we remind you that net income (loss)
reported on your cash flows statements already accounts for interest expense during each
respective period.
Note 2. Summary of Significant Accounting Policies
Cost of Goods Sold, page F-45
17.Please revise your disclosure to indicate if you include depreciation or amortization in
your cost of goods sold.  If you do not include depreciation or amortization in your cost of
goods sold, please revise your presentation to comply with SAB Topic 11:B, which would
include revising the cost of goods sold title and removing the gross profit subtotal
throughout the filing.  See SAB Topic 11:B.
Note 25. Subsequent Events, page F-64
18.Please disclose the actual date through which subsequent events have been evaluated.
Refer to ASC 855-10-50-1.

General
19.Please include a form of proxy which is marked clearly to indicate that it is preliminary.
See Rule 14a-6(e)(1) of Regulation 14A.
            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.
            You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866 or W. John

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corporation
 August 6, 2019 Page 5
 FirstName LastName
Yanming Liu
Greenland Acquisition Corporation
August 6, 2019
Page 5
Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions regarding comments on
the financial statements and related matters.  Please contact Edward M. Kelly, Senior Counsel, at
(202) 551-3728 or Jay E. Ingram, Legal Branch Chief, at (202) 551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

July
24, 2018

Securities
and Exchange Commission

100
F. Street, NE

Washington,
D.C. 20549

    Re:
    Greenland Acquisition
    Corporation

    Registration Statement on Form S-1

    File No. 333-226001

VIA
EDGAR

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933,
as amended, Chardan Capital Markets LLC, as representative of the underwriters, hereby requests acceleration of the effective
date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m., Washington D.C. time, on Tuesday,
July 24, 2018, or as soon thereafter as practicable.

The
following is supplemental information supplied under Rule 418(a)(7) and Rule 460 under the Securities Act of 1933:

    (i)
    Date
    of preliminary prospectus:  June 29, 2018.

    (ii)
    Dates
    of distribution:  July 16, 2018 through the date hereof.

    (iii)
    Number
    of prospective underwriters and selected dealers to whom the preliminary prospectus was furnished: 7.

    (iv)
    Number
    of prospectuses so distributed:  940.

The
undersigned confirms that it has complied with and will continue to comply with, and it has been informed or will be informed
by participating dealers that they have complied with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange
Act of 1934, as amended, in connection with the above-referenced issue.

[Signature
Page Follows]

CHARDAN
CAPITAL MARKETS LLC

By:
_/s/ George Kaufman________

Name:
George Kaufman

Title:
Managing Director

CORRESP
1
filename1.htm

Greenland Acquisition Corporation

Suite 906, Tower W1, Oriental Plaza,
No. 1 East Chang'an Street

Dongcheng District, Beijing

People’s Republic of China

July 24, 2018

VIA EDGAR

Division of Corporation
Finance

U.S. Securities &
Exchange Commission

100 F Street, NE

Washington, D.C. 20549-4561

Attn: Tonya K. Aldave

    Re:

    Greenland Acquisition Corporation

    Registration Statement on Form S-1

    Filed June 29, 2018, as amended

    File No. 333-226001

Dear Ms. Aldave:

Pursuant to Rule
461 under the Securities Act of 1933, as amended, Greenland Acquisition Corporation hereby requests acceleration of effectiveness
of the above referenced Registration Statement so that it will become effective at 4:00 p.m. EST on Tuesday, July 24, 2018, or
as soon as thereafter practicable.

    Very truly yours,

    /s/ Yanming Liu

    Yanming Liu

    Chief Executive Officer

    cc:

    Ellenoff Grossman & Schole LLP

    Loeb & Loeb LLP

CORRESP
1
filename1.htm

Greenland Acquisition Corporation

Suite 906, Tower W1, Oriental Plaza,
No. 1 East Chang’an Street

Dongcheng District, Beijing

People’s Republic of China

Division of Corporation Finance

Office of Transportation and Leisure

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Tonya K. Aldave

July 19, 2018

 Re: Greenland Acquisition Corporation

    Amendment No. 1 to Registration
Statement on Form S-1

    Filed July 16, 2018

    File No.
333-226001

Dear Ms. Aldave:

On behalf of Greenland Acquisition Corporation,
a British Virgin Islands company (the “Company”), we hereby transmit the Company’s response to the comment letter
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
on July 19, 2018, regarding the Amendment No. 1 to Registration Statement on Form S-1 submitted to the Commission on July 16, 2018.

For the Staff’s convenience, we have
repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.

Registration Statement on Form S-1

Exhibits

1. We note that the registration rights agreement filed as
Exhibit 10.7 includes an arbitration provision. Please tell us whether such provision applies to claims under the federal securities
laws.

We have revised exhibit 10.7  to remove the
arbitration provision.

We thank the Staff
for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel,
Stuart Neuhauser at sneuhauser@egsllp.com or by telephone at (212) 370-1300.

    Sincerely,

    /s/
    Yanming
    Liu

    Yanming
    Liu

July 19, 2018
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corp.
Suite 906, Tower W1, Oriental Plaza, No. 1 East Chang'an Street
Dongcheng District, Beijing
People’s Republic of China
Re:Greenland Acquisition Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed July 16, 2018
File No. 333-226001
Dear Mr. Liu:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-1
Exhibits
1.We note that the registration rights agreement filed as Exhibit 10.7 includes an arbitration
provision.  Please tell us whether such provision applies to claims under the federal
securities laws.

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corp.
 July 19, 2018 Page 2
 FirstName LastName
Yanming Liu
Greenland Acquisition Corp.
July 19, 2018
Page 2
            You may contact Aamira Chaudhry at (202) 551-3389 or Doug Jones at (202) 551-
3309 if you have questions regarding comments on the financial statements and related
matters.  Please contact Tonya K. Aldave at (202) 551-3601 or  Laura Nicholson, Special
Counsel, at (202) 551-3584 with any other questions.
Division of Corporation Finance
Office of Transportation and Leisure
cc:       Stuart Neuhauser, Esq.

May 4, 2018
Yanming Liu
Chief Executive Officer
Greenland Acquisition Corp.
Suite 906, Tower W1, Oriental Plaza, No. 1 East Chang'an Street
Dongcheng District, Beijing
People’s Republic of China
Re:Greenland Acquisition Corporation
Draft Registration Statement on Form S-1
Submitted April 9, 2018
CIK No. 0001735041
Dear Mr. Liu :
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1
General
1.Please provide us with copies of all written communications, as defined in Rule 405 under
the Securities Act, that you, or anyone authorized to do so on your behalf, present to
potential investors in reliance on Section 5(d) of the Securities Act, whether or not they
retain copies of the communications.

 FirstName LastNameYanming Liu
 Comapany NameGreenland Acquisition Corp.
 June 16, 2017 Page 2
 FirstName LastName
Yanming Liu
Greenland Acquisition Corp.
May 4, 2018
Page 2
Summary, page 1
2.We note your disclosure on page 5 that if you are unable to consummate your initial
business combination within the applicable time period, you will redeem the public shares
not more than ten business days thereafter.  However, elsewhere in your filing you make
reference to redemption within five business days if you are unable to complete your
initial business combination within the applicable time period.  Please advise.
Risk Factors, page 20
3.We note disclosure in your Risk Factors section that does not appear to apply to your
company.  For example, we note your reference on page 57 to the operation of your
variable interest entity in the online consumer finance marketplace industry, and we note
your disclosure on page 58 that you currently have no plans to pursue any acquisitions in
China or elsewhere in the world.  Please revise or advise how such disclosure relates to
your company.
Signatures, page II-5
4.Please revise your signature page to have your principal accounting officer or controller
and majority of your board of directors sign the registration statement in their individual
capacities.  These signatures should appear in the second signature block of the signature
section.  If someone has signed in more than one capacity, indicate each capacity in which
he or she has signed.
            You may contact Aamira Chaudhry at (202) 551-3389 or Doug Jones at (202) 551-
3309 if you have questions regarding comments on the financial statements and related
matters.  Please contact Tonya K. Aldave at (202) 551-3601 or Laura Nicholson at (202) 551-
3584 with any other questions.
Division of Corporation Finance
Office of Transportation and Leisure
cc: Stuart Neuhauser