September 3, 2019

Yanming Liu
Chief Executive Officer
Greenland Acquisition Corporation
Suite 906, Tower W1, Oriental Plaza, No. 1 East
Chang'an Street
Dongcheng District
Beijing, People's Republic of China

       Re: Greenland Acquisition Corporation
           Revised Preliminary Proxy Statement on Schedule 14A
           Filed August 21, 2019
           File No. 1-38605

Dear Mr. Liu:

       We have reviewed your filing and have the following comments. In some of
our
comments we may ask you to provide us information so that we may better
understand your
disclosure.

       Please respond to these comments within 10 business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe that
our comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Revised Preliminary Proxy Statement on Schedule 14A filed August 21, 2019

Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Period
Ended June 30,
2019
Note 7 - Property, Plant and Equipment, page F-53

1.     Please revise your presentation to ensure the total amounts of property,
plant and
       equipment, net are properly displayed within the table on page F-53.
Financial Statements of Zhongchai Holding (Hong Kong) Limited for the Year
Ended December
31, 2018
Note 25 - Subsequent Events, page F-91

2.     We have reviewed your response to prior comment 18. We note that you
have now
 Yanming Liu
Greenland Acquisition Corporation
September 3, 2019
Page 2
         disclosed the actual date through which subsequent events have been
evaluated. Please
         revise your disclosure here and on page F-60 to disclose also whether
the date through
         which subsequent events have been evaluated is the date the financial
statements were
         issued or the date the financial statements were available to be
issued. Refer to ASC 855-
         10-50-1.
        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.

        You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866
or W. John
Cash, Accounting Branch Chief, at (202) 551-3768 if you have questions
regarding comments on
the financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
(202) 551-3728 or Jay E. Ingram, Legal Branch Chief, at (202) 551-3397 with any
other
questions.



                                                              Sincerely,
FirstName LastNameYanming Liu
                                                              Division of
Corporation Finance
Comapany NameGreenland Acquisition Corporation
                                                              Office of
Manufacturing and
September 3, 2019 Page 2                                      Construction
FirstName LastName