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                             February 15, 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. 16 to
Registration Statement on Form S-1
                                                            Filed January 28,
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
December 29, 2021 letter.

       Amendment No. 16 to Registration Statement on Form S-1 Filed January 28,
2022

       Risk Factors
       "A joint statement by the SEC and the Public Company Accounting ... ",
page 13

   1.                                                   Please update your
disclosure to reflect that the Commission adopted rules to implement
                                                        the HFCAA and that,
pursuant to the HFCAA, the PCAOB has issued its report notifying
                                                        the Commission of its
determination that it is unable to inspect or investigate completely
                                                        accounting firms
headquartered in mainland China or Hong Kong.
       General

   2.                                                   We note your current
disclosure regarding the Holding Foreign Companies Accountable
                                                        Act. On the Cover Page
and in the Prospectus Summary, please disclose whether your
 Hong Zhida
Addentax Group Corp.
February 15, 2022
Page 2
      auditor is subject to the determinations announced by the PCAOB on
December 16, 2021
      and whether and how the Holding Foreign Companies Accountable Act and
related
      regulations will affect your company. In your Prospectus Summary,
disclose that trading
      in your securities may be prohibited under the Holding Foreign Companies
Accountable
      Act if the PCAOB determines that it cannot inspect or investigate
completely your
      auditor, and that as a result an exchange may determine to delist your
securities.
3.    Please update your prospectus cover page for your selling shareholder
offering to include
      the same disclosure related to your operations in China that you include
on your
      prospectus cover page for your firm commitment offering.
       Please contact Cara Wirth at (202) 551-7127 or Erin Jaskot at (202)
551-3442 with any
questions.



                                                           Sincerely,
FirstName LastNameHong Zhida
                                                           Division of
Corporation Finance
Comapany NameAddentax Group Corp.
                                                           Office of Trade &
Services
February 15, 2022 Page 2
cc:       Lawrence Venick
FirstName LastName