 During August 1938, it advanced along railroad to Nanxun District, and in September 1938 was heavily engaged in the Battle of Wanjialing.The 106th artillery regiment was stuck in mountainous terrain, therefore was unable to provide any fire support from 20 September 1938, and entire division suffered heavy losses after its parts has been encircled in Lianxi District.Five of the eight regiments were routed 24 September - 13 October 1938, and division suffered an 11,164 casualties (over half of total strength).