I don't know where you got 39.4mm but here's how I do it: 65mm / 2 = 32.5mm add 3mm for lens cover = 35.5 (this is what you need to clear the barrel).
Your base is 11.3mm and ring height from scope center to bottom of the rings is 21.3mm, so your total height (rings + base) = 11.3mm + 21.3mm equals to 32.6mm but you need 35.5mm clear the barrel so you are still short of -2.9mm.
However, these measurements are obtained from the top of the action and you barrel should tapers from the chamber to the muzzle and that should make up the difference of 3mm.
Do you have the rifle and scope with you?
The easiest way to do is put your rifle in a cleaning vise stack up some quarters put the scope on top after you satisfied with the height you want measure the thickness of the quarters and minus the height of the rail and you've got the measurements on how tall a set of rings you need.
Copy and paste this link here:
http://snipersparadise.com/bits-o-wisdom/basics/81-easy-accurate-scope-height-measurment



























