Assessee engaged in real estate business, allotted 1.25 lakh equity shares to another company.  Shares were issued at a premium. The AO  held that the FMV of shares was determined at Rs. 3560.77 per share as per rule 11UA, but shares were issued at Rs. 3600 per share and made the addition of Rs. 48.75 lakh based on a differential of Rs. 39 per share under section 56(2)(viib) of the Act. CIT (A) affirmed the order of AO. On appeal, the Tribunal held that provisions of section 56(2)(viib) or rule 11UA nowhere provides for rounding off to nearest rupee or multiple of ten or hundred. If the legislature intended to provide rounding off it would be specifically provided under section 56(2)(viib) of the Act. Accordingly, addition made on account of the difference between FMV and actual consideration received by assessee in terms of section 56(2)(viib) was justified. (AY. 2014-15)