April 16, 2026
Hongliang Li
Chief Executive Officer
Leishen Energy Holding Co., Ltd.
103 Huizhong Li, B Building, Peking Times Square, Unit 15B10
Chaoyang District, Beijing, China
Re: Leishen Energy Holding Co., Ltd.
Form 20-F for Fiscal Year Ended September 30, 2025
Filed January 30, 2026
File No. 001-42445
Dear Hongliang Li:
We have limited our review of your filing to the financial statements
and related
disclosures 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.
Form 20-F for Fiscal Year Ended September 30, 2025
Item 15. Controls and Procedures
Management s Annual Report on Internal Control over Financial Reporting and
Attestation
Report of the Registered Public Accounting Firm, page 90
1. As the company has previously filed an annual Form 20-F, it no longer
meets the
exemption requirements. Please amend the filing to provide management
s annual report
on internal control over financial reporting as required by Part II,
Item 15(b) of the Form
20-F. Please ensure the amendment includes updated certifications that
refer to the Form
20-F/A.
April 16, 2026
Page 2
Index to Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 20 Segment Information, page F-31
2. Please amend your filing to provide the segment information required by
Accounting
Standard Update 2023-07 or explain why you believe you are not subject
to the
amendments in the Update. To the extent you agree the Update is
applicable in the
current period, please provide all disclosures required by ASC
280-10-50, including:
The title and position of the individual or the name of the group or
committee
identified as the chief operating decision maker. See ASC
280-10-50-21(c).
Each segment s measure(s) of profit or loss used by the chief
operating decision
maker (CODM) in assessing segment performance and allocating
resources. See
ASC 280-10-50-28A and 50-29.f.
Disclosures that reconcile the segmented information with
consolidated financial
information for each period an income statement is presented, as
required by ASC
280-10-50-30 and 50-31.
Significant expense categories that are regularly reviewed by the
CODM and
included in reported segment profit or loss in accordance with ASC
280-10-50-26A.
If you do not disclose significant expense categories for one or
more reportable
segments, explain the nature of the expense information the CODM
uses to manage
operations. See ASC 280-10-50-26C.
Disclose amounts of other segment items that may be required by ASC
280-10-50-
26B, as applicable.
In closing, 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 Myra Moosariparambil at 202-551-3796 or Kimberly Calder at
202-551-
3701 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation