Dismissing the appeal of the revenue the Tribunal held  that  running a pharmacy in the hospital was an independent business activity, and therefore, the profit earned ought to be separately assessed. The hospital provided various services for 24-hours in various medical fields. Therefore, it was more necessary and was a duty on the part of the trust to run its medical stores to provide medicines to patients as prescribed by the doctors. The hospital ran medical shops for 24-hours in order to meet the emergency requirements of patients, who were admitted in the emergency. The assessee had maintained separate books of account and these were produced before the Assessing Officer. 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. No change of facts denial of exemption was not justified. (AY. 2014-15)