Interest paid on Loan cannot be set off against interest earned on Fixed Deposit

Smt. Zeelia Zeena Mayzean Shenoy Vs ITO (ITAT Bangalore) The issue under consideration is whether or not income paid on interest against the fixed deposits can be said to have been incurred ‘wholly and exclusively’ for the purpose of earning interest income from fixed deposits? In the present case, the assessee made fixed deposit with various banks amounting to Rs.15 crore. At the same time, the assessee availed loan amounting to Rs.2.5 crore from State Bank of India and claimed the interest of Rs.25,16,005 to be set off against the interest received from various banks from fixed d...