April 23, 2019

Xiao Jun Kong
Chief Executive Officer
Trafalgar Resources, Inc.
Everbright Center, Suite 3102
108 Gloucester Road
Wanchai, Hong Kong

       Re: Trafalgar Resources, Inc.
           Form 10-K for the Fiscal Year Ended September 30, 2018
           Filed January 9, 2019
           Form 10-Q for the Fiscal Quarter Ended December 31, 2018
           Filed February 13, 2019
           File No. 001-32522

Dear Mr. Kong:

       We have reviewed your filing 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 these comments 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 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.

Form 10-K for the Fiscal Year Ended September 30, 2018

Report of Independent Registered Public Accounting Firm, page 11

1.    Please amend the filing to also include an auditor's report that covers
the audited financial
      statements as of and for the year ended September 30, 2017. Refer to Rule
8-02 of
      Regulation S-X. Your amendment should include all items of Form 10-K as
well as the
      required certifications.
 Xiao Jun Kong
FirstName LastNameXiao Jun Kong
Trafalgar Resources, Inc.
Comapany NameTrafalgar Resources, Inc.
April 23, 2019
Page 23,
April 2 2019 Page 2
FirstName LastName
Exhibits

2.       We note the certification provided in Exhibit 31.1 does not include
the introductory
         language in paragraph 4 referring to your internal control over
financial reporting. Please
         note that you are no longer in the transition period that allows for
this omission. In your
         amended filing, provide an updated and corrected Section 302
certification.
Form 10-Q for the Fiscal Quarter Ended December 31, 2018

Exhibits

3.       We note the certification provided in Exhibit 31.1 does not include
paragraph 4(b) and the
         introductory language in paragraph 4 referring to internal control
over financial reporting.
         Please amend the filing to provide a corrected Section 302
certification. You may file an
         abbreviated amendment that is limited to the cover page, explanatory
note, signature page
         and paragraphs 1, 2, 4 and 5 of the certification.
        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 Gary Newberry at (202) 551-3761 or Kevin Kuhar,
Accounting Branch
Chief, at (202) 551-3662 with any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Electronics and Machinery