Section 56(2)(viib) or Rule 11UA not provides for rounding off of FMV of Shares

Royal Accord Realtors Pvt. Ltd. Vs DCIT (ITAT Mumbai)

In a taxing statute one has to look merely at what is clearly said in the section. There is no room for any intendment. There is no concept of equity in tax law. Nothing is to be read in, nothing is to be implied. One has to look at plain language of the provisions of the section. For the purpose of construction of a taxing statute, the context, scheme of the relevant provision as a whole and its purpose is relevant. Where the statute is absolutely clear and unambiguous,

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