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                             August 3, 2022

       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. 21 to
Registration Statement on Form S-1
                                                            Filed July 26, 2022
                                                            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 March
22, 2022 letter.

       Amendment No. 21 to Registration Statement on Form S-1 Filed July 26,
2022

       PRC Limitation on Overseas Listing and Share Issuances, page 8

   1.                                                   Please revise your
disclosure in the first sentence to clarify that "Neither we nor our
                                                        subsidiaries are
currently required to obtain approval from Chinese authorities...," to the
                                                        extent accurate. In
addition, where you state that each of your PRC Subsidiaries has
                                                        received all requisite
permissions in order to conduct and operate your business, please
                                                        expand your disclosure
to include approvals and also disclose that you and your non-PRC
                                                        subsidiaries have also
received all such requisite permissions and approvals, to the extent
                                                        accurate.
 Hong Zhida
FirstName  LastNameHong Zhida
Addentax Group  Corp.
Comapany
August     NameAddentax Group Corp.
       3, 2022
August
Page 2 3, 2022 Page 2
FirstName LastName
Risk Factors
"Failure to make adequate contributions to various employee benefits plans ...
", page 18

2.       We note your amended disclosure regarding your failure to make social
insurance and
         housing fund contributions in full for all your employees, as required
by PRC laws and
         regulations. Please revise to disclose whether this failure could
impact your ability to
         operate your business or interfere with your ability to offer the
securities being registered
         to foreign investors. Additionally, we note that your PRC counsel has
given an opinion on
         this issue. Please revise to name your PRC counsel here, and elsewhere
throughout your
         prospectus where you indicate that the statement or disclosure is
attributed to
         counsel. Finally, we note that certain matters governed by PRC law are
being passed
         upon by Dahui Lawyers. Please revise the prospectus, as appropriate,
to clarify which
         statements, if any, are the opinion of Dahui Lawyers and file their
consent as an exhibit.
       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 Trade
& Services
cc:      Lawrence Venick