CIT v. Secure Meters Ltd.

321 ITR 611High Court2010#1498 most cited

What is CIT v. Secure Meters Ltd. authority for?

Expenditure incurred on the issuance of debentures, including convertible debentures like Compulsorily Convertible Debentures (CCDs) or Foreign Currency Convertible Bonds (FCCBs), is revenue in nature and thus deductible. This is because a debenture constitutes a loan at the time of its issue, regardless of its future convertibility into equity.

76

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Secure Meters Ltd. · Secure Meters Ltd. · 321 ITR 611 · debenture issuance expenditure · convertible debentures nature · foreign currency convertible bonds · compulsorily convertible debentures · revenue expenditure deduction · loan classification · expenditure on debenture issue · India Cements Ltd. precedent

Also reported as

221 CTR 405

Sections most often in play

Section 115JBSection 14ASection 1961Section 115USection 244ASection 271(1)(c)Section 36(1)(vii)Section 36(1)(viia)

Issues it is cited on

section 50(1)section 80absection 54esection 70(2)section 10(15)section 80msection 10(33)section 14a(1)section 54eclong-term capital assetsection 36(1)(viii)section 111a

Judgments citing CIT v. Secure Meters Ltd.

COUNTRY CLUB HOSPITALITY & HOLIDAYS LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, the appeal filed by the assessee is partly allowed

ITA 1480/HYD/2025[2011-12]Status: DisposedITAT Hyderabad27 Mar 2026AY 2011-12
Section 139Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250

…axman 249 (MP) (HC) 3. CIT vs. East India Hotels Ltd., (2001) 119 Taxman 235 (Cal.) 4. CIT vs. South India Corpn. (Agencies) Ltd., (2007) 164 Taxman 249 (Mad.) 5. CIT vs. First Leasing Co. of India Ltd., (2008) 304 ITR 67 (Mad.) 6. CIT vs. Secure Meters Ltd., 321 ITR 611 7. CIT vs. ITC Hotels Ltd., 334 ITR 109 8. M/s. Crane Software International Ltd. vs. DCIT, Bangalore Order dated 08.02.2011 in ITA.Nos. 741 & 742/Bang/2010. 9. CIT vs. Havells India Ltd., 352 ITR 376 10. DCIT vs. UAG Builders (P) Ltd., Delhi (2012) 25 taxmann.com 205 (Del.) 3.1. Further he has also relied upon the CBDT circular No.56 dated 19th…

MOVATE TECHNOLOGIES PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI

In the result the appeal of the Assessee is partly allowed for statistical purposes

ITA 2467/CHNY/2024[AY 2020-21]Status: DisposedITAT Chennai16 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Vikram Vijayaraghavan, AdvocateFor Respondent: Shri. ARV Sreenivasan, CIT
Section 143(3)Section 144CSection 144C(5)Section 92C

…t has been a judicially well settled proposition that CCDs constitute debt and interest payable thereon is a deductible expenditure till the time the same are converted into equity. The Hon’ble Rajasthan High Court in the case of Secure Meters Ltd reported in 321 ITR 611 (Raj), held that the debentures when issued is a loan, and therefore, whether it is convertible, or non-convertible, does not militate against the nature of the debenture, being loan. :-9-: ITA. No:2467/Chny/2024 10.5 Further the Ld.AR also pointed out that the TPO and the DRP have held that since the adjustment was made in A.Y.2018-19 and it i…

GOLDMAN SACHS (INDIA) FINANCE PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NEW DELHI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

ITA 6766/MUM/2024[AY 2021-22]Status: DisposedITAT Mumbai22 Aug 2025
For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(1)Section 144C(5)Section 253Section 32Section 37(1)

…g the hearing, the learned AR placed reliance upon various\ndecisions, wherein it has been held that CCDs are in the nature of debt until\nthe date of conversion. We find that the Hon'ble Rajasthan High Court in CIT\nvs. Secure Meters Ltd., reported in (2010) 321 ITR 611 (Raj.), held that a\nde benture when issued, is a loan, and therefore, whether it is convertible or\nnon-convertible, thus the same does not militate against the nature of the\nde benture being the loan. Accordingly, the Hon'ble Rajasthan High Court,\nfollowing the decision of the Hon'ble Supreme Court in India Cements Ltd. Vs.\nCIT, reported in…

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LTD ( MERGED ENTITY HDFC INVESTMENTS LIMITED ), MUMBAI

ITA 2980/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Jan 2025AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate a

…o equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully followin…

HDFC BANK LIMITED (AS SUCCESSOR TO HDFC LTD),MUMBAI vs. DCIT 2(3)(1), MUMBAI

ITA 2665/MUM/2024[2015-16]Status: DisposedITAT Mumbai28 Jan 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

Section 143(3)

…o equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following…

ACIT-2(3)(1), MUMBAI vs. HDFC BANK LIMITED (MERGED ENTITY HOUSING DEVELOPMENT FINANCE CORPORATION LIMITED), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below:\n\nSr

ITA 2597/MUM/2024[2020-21]Status: DisposedITAT Mumbai28 Jan 2025AY 2020-21

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2049/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

…into equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18.3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the ab…

ACIT-1(1)(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPORATION LTD., DELHI

ITA 2047/MUM/2023[2018-19]Status: DisposedITAT Mumbai28 Jan 2025AY 2018-19

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully foll…

ACIT-1(1)(1), MUMBAI vs. M/S HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 2046/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Jan 2025AY 2017-2018

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and

…o equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully followin…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD.),MUMBAI vs. DCIT, RANGE-1(1)(2), MUMBAI

ITA 1890/MUM/2023[2016-17]Status: DisposedITAT Mumbai28 Jan 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi

…o equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully followin…

DCIT RANGE-1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

ITA 5110/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RANGE-1(1)(2), MUMBAI

ITA 4983/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Jan 2025AY 2013-14

…o equity at a later date,\nyet on the date of its issue, it is a loan. Therefore, expenditure incurred\nthereon is revenue in nature.” Reliance was also placed on the decision\nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters\nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of\nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del).\n\n18. 3. On the given set of facts and judicial precedents discussed above,\nRevenue could not submit any reason as to why a different view on this\nissue should be taken as taken by various Hon'ble High Courts.\nAccordingly, respectfully followi…

DCIT - 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORARTION LTD., MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

ITA 2861/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Jan 2025AY 2011-12

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\nSr

ITA 2609/MUM/2017[2011-12]Status: DisposedITAT Mumbai28 Jan 2025AY 2011-12

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

DCIT 1(1)(2), MUMBAI vs. HOUSING DEVELOPMENT FINANCE CORPORATION LTD, MUMBAI

Accordingly, ground so raised for Assessment \nYear 2004-05 is dismissed as infructuous

ITA 2326/MUM/2017[2009-10]Status: DisposedITAT Mumbai28 Jan 2025AY 2009-10

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

In the result, appeals of both, assessee and revenue are decided \nas per the table below: \n\n| Sr

ITA 2093/MUM/2017[2009-10]Status: DisposedITAT Mumbai28 Jan 2025AY 2009-10

…uity at a later date, \nyet on the date of its issue, it is a loan. Therefore, expenditure incurred \nthereon is revenue in nature.” Reliance was also placed on the decision \nof Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters \nLtd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of \nCIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). \n\n18. 3. On the given set of facts and judicial precedents discussed above, \nRevenue could not submit any reason as to why a different view on this \nissue should be taken as taken by various Hon'ble High Courts. \nAccordingly, respectfully fo…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT 1(1), MUMBAI

ITA 2867/MUM/2012[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…into equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18.3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the a…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

ITA 5033/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jan 2025AY 2006-07

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…into equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18.3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the a…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

ITA 4314/MUM/2010[2003-04]Status: DisposedITAT Mumbai28 Jan 2025AY 2003-04

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

…into equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18. 3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the…

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

ITA 4313/MUM/2010[2002-03]Status: DisposedITAT Mumbai28 Jan 2025AY 2002-03

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Shri Nitesh Joshi, Advocate and Shri Ninad Patade, CAFor Respondent: Shri Biswanath Das, CIT DR
Section 1

…into equity at a later date, yet on the date of its issue, it is a loan. Therefore, expenditure incurred thereon is revenue in nature.” Reliance was also placed on the decision of Hon'ble Rajasthan High Court in the case of CIT vs. Secure Meters Ltd., [2010] 321 ITR 611 (Raj) and Hon'ble Delhi Court in the case of CIT vs. Havells India Ltd., [2013] 352 ITR 376 (Del). 18.3. On the given set of facts and judicial precedents discussed above, Revenue could not submit any reason as to why a different view on this issue should be taken as taken by various Hon'ble High Courts. Accordingly, respectfully following the a…

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CIT v. Secure Meters Ltd. (321 ITR 611) — Cited in 76 Judgments | BharatTax