Assessee transferred its business and filed nil return. Assessee claimed credit for TDS on income which was not offered for assessment. The Assessing Officer denied the credit of TDS on the ground that the assessee had transferred its income and it had shown nil income.Order of AO was affirmed by CIT(A) and Tribunal. On appeal the Court held that  there could not be a situation that principal income corresponding to TDS as claimed, was not offered for assessment as a NIL return was filed, however, merely benefit of TDS income was claimed. Such incongruence and a position contrary to return of assessee went contrary to provisions of section 198 read with section 199 and thus, credit for TDS was rightly denied to the assessee.  Order of Tribunal affirmed. (AY. 2006-07)