United States securities and exchange commission logo January 10, 2024 Ricardo Lewin Chief Financial Officer Cosan S.A. Av. Brigadeiro Faria Lima, 4,100 16th floor S o Paulo SP, 04538-132, Brazil Re: Cosan S.A. Form 20-F for the Fiscal Year Ended December 31, 2022 Form 6-K Furnished on August 15, 2023 Response dated December 22, 2023 File No. 1-40155 Dear Ricardo Lewin: We have reviewed your December 22, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our December 4, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Note 18. Net Sales, page F-122 1. We note your response to prior comment 1. Please tell us how your presentation of gross revenue from products and services on page F-125 complies with IFRS 15 and why the indirect taxes and deductions have not been allocated to the individual sources of revenue presented. Form 6-K Furnished on August 15, 2023, page G-17 2. We note your response to prior comment 6. Reference is made to footnote (a). We note you make these adjustments to calculate Ra zen Adjusted EBITDA and Ra zen Adjusted Net Income so that investors receive consistent and comparable information from the Company and Ra zen. Please tell us the related authoritative literature you are relying on Ricardo Lewin Cosan S.A. January 10, 2024 Page 2 to present such adjustments to your Ra zen non-GAAP financial measures. In addition, please explain why consolidating Ra zen and adjustments (2) and (4)(i) in your reconciliation of Ra zen Adjusted Net Income and similar adjustments to Ra zen Adjusted EBITDA do not result in individually tailored measures. In doing so, please elaborate on the nature and quantify each adjustment to the extent needed to provide a full understanding. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 3. We note your response to prior comment 6. Please explain why adjustment (6) in your reconciliation of Adjusted Net Income related to the accounting impacts generated by the acquisition of an equity stake under the Cosan Oito column does not result in an individually tailored measure. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please contact Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters. FirstName LastNameRicardo Lewin Sincerely, Comapany NameCosan S.A. Division of Corporation Finance January 10, 2024 Page 2 Office of Trade & Services FirstName LastName