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                              January 10, 2024

       Ricardo Lewin
       Chief Financial Officer
       Cosan S.A.
       Av. Brigadeiro Faria Lima, 4,100     16th floor
       S  o Paulo     SP, 04538-132, Brazil

                                                        Re: Cosan S.A.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Form 6-K Furnished
on August 15, 2023
                                                            Response dated
December 22, 2023
                                                            File No. 1-40155

       Dear Ricardo Lewin:

              We have reviewed your December 22, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our December 4,
       2023 letter.

       Form 20-F for the Fiscal Year Ended December 31, 2022

       Note 18. Net Sales, page F-122

   1.                                                   We note your response
to prior comment 1. Please tell us how your presentation of gross
                                                        revenue from products
and services on page F-125 complies with IFRS 15 and why the
                                                        indirect taxes and
deductions have not been allocated to the individual sources of revenue
                                                        presented.
       Form 6-K Furnished on August 15, 2023, page G-17

   2.                                                   We note your response
to prior comment 6. Reference is made to footnote (a). We note
                                                        you make these
adjustments to calculate Ra  zen Adjusted EBITDA and Ra  zen Adjusted
                                                        Net Income so that
investors receive consistent and comparable information from the
                                                        Company and Ra  zen.
Please tell us the related authoritative literature you are relying on
 Ricardo Lewin
Cosan S.A.
January 10, 2024
Page 2
         to present such adjustments to your Ra  zen non-GAAP financial
measures. In addition,
         please explain why consolidating Ra  zen and adjustments (2) and
(4)(i) in your
         reconciliation of Ra  zen Adjusted Net Income and similar adjustments
to Ra  zen Adjusted
         EBITDA do not result in individually tailored measures. In doing so,
please elaborate on
         the nature and quantify each adjustment to the extent needed to
provide a full
         understanding. Refer to Question 100.04 of the Non-GAAP Financial
Measures
         Compliance and Disclosure Interpretations.
3.       We note your response to prior comment 6. Please explain why
adjustment (6) in your
         reconciliation of Adjusted Net Income related to the accounting
impacts generated by the
         acquisition of an equity stake under the Cosan Oito column does not
result in
         an individually tailored measure. Refer to Question 100.04 of the
Non-GAAP Financial
         Measures Compliance and Disclosure Interpretations.
       Please contact Tony Watson at 202-551-3318 or Adam Phippen at
202-551-3336 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameRicardo Lewin                              Sincerely,
Comapany NameCosan S.A.
                                                             Division of
Corporation Finance
January 10, 2024 Page 2                                      Office of Trade &
Services
FirstName LastName