Mail Stop 3030
                                                                 August 10,
2018


     Via E-mail
     Aron Govil
     Executive Director
     Cemtrex, Inc.
     19 Engineers Lane
     Farmingdale, NY 11735

            Re:      Cemtrex, Inc.
                     Registration Statement on Form S-3
                     Response dated July 30, 2018
                     File No. 333-224379

     Dear Mr. Govil:

            We have reviewed your July 30, 2018 response and have the following
comment. In our
     comment, 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 comment applies 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 this comment, we may have additional comments. Our
references to prior
     comments are to comments in our May 8, 2018 letter.

     Incorporation of Certain Documents by Reference, page 7

     1.     We note your response to comment one. Please address the following:

                  Explain why the fiscal year 2016 consolidated and AIS assets
are different from the
                  amounts reported in the September 30, 2016 Form 10-K, noting
that for the purposes
                  of determining whether the other auditor played a substantial
role under PCAOB Rule
                  1001(p)(ii) the determination for fiscal year 2017 should be
made using fiscal year
                  2016 information; and
                  Tell us whether the other auditor for the AIS audit
constituted 20% or more of the
                  total audit fee for either fiscal years.
 Aron Govil
Cemtrex, Inc.
August 10, 2018
Page 2

       If a determination is made that Bharat Parikh & Associates needs to
continue to make
       reference to the other auditor in their audit report, please include the
report of the other
       auditors as required by Rule 2-05 of Regulation S-X. In addition, revise
this filing to
       include a consent from the other auditors for the use of their report
and any reference to
       them in the expert section. Last, if it is determined that the other
auditor played a
       substantial role under PCAOB Rule 1001(p)(ii) in fiscal year 2016 or
2017 consolidated
       audit, please confirm that the other auditor is registered with the
PCAOB.

       You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio,
Accounting
Branch Chief, at (202) 551-3676 if you have questions regarding comments on the
financial
statements and related matters. Please contact Caleb French at (202) 551-6947
or me at (202)
551-3617 with any other questions.

                                                             Sincerely,

                                                             /s/ Russell
Mancuso

                                                             Russell Mancuso
                                                             Branch Chief
                                                             Office of
Electronics and Machinery

cc:    Spencer G. Feldman, Esq.
       Olshan Frome Wolosky LLP