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Exemption u/s 11 - whether the assessee is to be treated as a “charitable institution”? - Running a Hospital / Medical institution - generating huge profit - The equipments require higher lay out of the capital, and therefore in order to remain in competition with the hospitals, and to provide best facility to the patients, and to provide medical help, the assessee has to upgrade its investigative tools. - Rates considered by the AO are not relevant rates for determining higher range of profit in the hands of the assessee. - AT