Assessee, a joint owner of immovable property, filed a writ petition to restrain Income Tax Department from proceeding with sale of attached property. Sale was based on an attachment order and an order under section 179, holding assessee jointly and severally liable for tax dues of certain company.  The assessee had not challenged order under Section 179 holding her jointly and severally liable with said company.  Further she had also not challenged attachment order based on which proclamation was issued.  Assessee had also not bothered to implead company as a party, though; record showed a very close nexus between her and this company and without challenging foundational orders, attempt was to stall proclamation and sale by alleging the bar of limitation  High Court held that in fiscal matters, there is no justification for granting unconditional interim reliefs merely upon Petitioner making out a prima facie case and aspects of balance of convenience must also be considered and here, assuming that a prima facie arguable case was made out, still, balance of convenience did not favour grant of an unconditional stay.  Thus, considering all those factors cumulatively, ad. interim orders granted earlier could be confirmed if assessee would deposit 50% of demanded amount with department within eight weeks of today and if no such deposit was made within eight weeks of today, this interim order would stand vacated without further reference to this Court.  Against the order of High Court the   assessee filed SLP. Supreme Court dismissed the SLP.