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                             October 4, 2021

       Hong Zhida
       Chief Executive Officer
       Addentax Group Corp.
       Kingkey 100, Block A, Room 5403
       Luohu District, Shenzhen City, China 518000

                                                        Re: Addentax Group
Corp.
                                                            Amendment No. 12 to
Registration Statement on Form S-1
                                                            Filed September 16,
2021
                                                            File No. 333-230943

       Dear Mr. Zhida:

             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.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 1, 2021 letter.

       Amendment No. 12 to Registration Statement on Form S-1 Filed September
16, 2021

       Cover Page

   1.                                                   We note your response
to comment 1 and we reissue it in part. Please revise to note the
                                                        risks associated with
being based in or having the majority of your operations in China
                                                        and that these risks
could case the value of your securities to significantly decline or be
                                                        worthless. Also, please
revise to address how recent statements and regulatory actions by
                                                        China's government,
such as those related to data security or anti-monopoly concerns, has
                                                        or may impact your
ability to conduct your business, accept foreign investments or list on
                                                        an U.S. or other
foreign exchange.
   2.                                                   We note your response
to comment 2 and reissue it in part. Please revise your cover page
                                                        to state that you are
not a Chinese operating company. Also, please disclose that investors
 Hong Zhida
Addentax Group Corp.
October 4, 2021
Page 2
         may never directly hold equity interests in your Chinese operating
entities. Your
         disclosure should acknowledge, if true, that Chinese regulatory
authorities could disallow
         your operating structure, which would likely result in a material
change in your operations
         and/or the value of your common stock, including that it could cause
the value of such
         securities to significantly decline or become worthless.
Summary, page 2

3.       Please revise to clearly disclose how you will refer to your
subsidiaries. We note defined
         terms for your subsidiaries throughout your prospectus, including in
your Risk Factors,
         Current Business, and Business sections. For example, the defined term
for Qianhai
         Yingxi Textile & Garments Co., Ltd., which you refer to as your WFOE,
first appears on
         page 17. Further, please also define the term "WFOE" so that investors
can understand
         this reference. Please revise so that the defined terms for all of
your subsidiaries appear in
         the Summary section in the first instance.
4.       We note your response to comment 4 and reissue it in part. Please
revise to include
         specific cross-references between the risks discussed in your Risk
Factor Summary
         and the more detailed risks discussed in the Risk Factors section.
Also, please revise both
         sections to specifically discuss the risks arising from the legal
system in China, including
         risks and uncertainties regarding the enforcement of laws and that
rules and regulations in
         China can change quickly with little advance notice.
5.       We note your revised disclosure in response to our prior comment 5 and
your disclosure
         on page 17 that, based on the advice of PRC counsel, you believe that
CSRC approval is
         not required for this offering, given that the CSRC currently has not
issued any definitive
         rule or interpretation concerning whether "offerings like ours" are
subject to the
         regulation. Please revise to explain what is meant by "offerings like
ours." Please discuss
         any efforts you have undertaken to determine whether approval is
required, and explain
         why you believe it is appropriate to move forward with this offering
without a definitive
         answer to the question of approval.
6.       We note your response to our prior comment 6. Please also quantify any
cash flows and
         transfers of other assets by type that have occurred between the
holding company and its
         subsidiaries, and the direction of transfer.
Our  Corporate
FirstName      Structure, page
           LastNameHong         3
                            Zhida
Comapany
7.         NameAddentax
       Please                Group
              revise to indicate theCorp.
                                     percentage ownership of the public
shareholders and other
       shareholders in
October 4, 2021 Page 2 Addentax    Group Corp., following the offering.
FirstName LastName
 Hong Zhida
FirstName  LastNameHong Zhida
Addentax Group  Corp.
Comapany
October    NameAddentax Group Corp.
        4, 2021
October
Page 3 4, 2021 Page 3
FirstName LastName
       Please contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202)
551-3442 with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences
cc:      Lawrence Venick