Assessee filed an application before Tribunal for stay of outstanding demand. Tribunal directed assessee to pay entire outstanding in instalments of Rs. 50 lakhs in every English calender month. On writ the High Court held that The Tribunal did not record any finding that assessee had not made out a prima facie case.  So far as aspect of hardship was concerned, Tribunal itself was conscious of fact that on account of attachment of bank account, assessee was put to hardship. As regards third aspect namely balance of convenience, same had not been adverted to by Tribunal.  High Court thus taking a view that in case entire balance outstanding was directed to be paid, to deposit a sum of Rs. 3 crores out of total tax demand in three instalments.  (AY. 2009-10 to 2015-16)