Assessee has raised the groundthat the Ld. Commissioner of Income Tax (Appeals) has erred on law and on facts in confirming the addition of Rs. 51,72,597/- u/s 14A r.w.r. 8D, in respect of investments from which the appellant has not earned any exempt income, disregarding the orders passed by Commissioner of Income Tax (Appeals) in earlier years and also disregarding the decision of Hon’ble Gujarat High Court in thecaseof Corrtech Energy Private Limited reported at 45 taxman.com 116 (Gujarat).