Tribunal held that the maintenance of a pharmacy had been considered as ancillary to the object of running a hospital for the past more than 12-13 years. Therefore, it was to considered an integral part of the hospital activity. That the Assessing Officer had compared the profit rate of hospitals who were provided subsidies from the Government. The rates of such hospital could not be compared with the rates of the assessee, which had to take care of day-to-day operational expenses, and future expansion in the area of investigative tools, viz., x-ray machines, CT-scan, etc. These items of equipment required higher outlay of capital, and therefore in order to remain in competition with the hospitals, and to provide the best facility to the patients, and to provide medical help, the assessee had to upgrade its investigative tools. Therefore, the rates considered by the Assessing Officer were not relevant rates for determining higher range of profit in the hands of the assessee. The unit of advance gastroenterology set up in March, 2012 on rented premises became unviable, and therefore it was to be closed down, which was very much part of the assessee-hospital. The Assessing Officer had not pointed out any defect in the books of account and had not brought any material on record on account of disallowance of expenses. On the one hand, the Assessing Officer accepted the receipt of Rs. 5,09,900, but on the other hand, disallowed the entire expenditure incurred by the trust at Rs. 1,72,42,642. The assessee also submitted that a similar loss for the assessment years 2013-14 and 2015-16 was accepted by the Assessing Officer. Therefore, the Assessing Officer was not justified in denying the claim in the absence of any material finding.( AY. 2014-15)