Section 253 of the Income-tax Act, 1961—Appellate Tribunal - While granting an interim order, what is required to be seen is as to whether the assessee made out a prima facie case, as to whether the balance of convenience is in favour of the assessee and as to whether the assessee will be put to irreparable hardship if the interim order is not granted and further, the Tribunal does not record any finding that the assessee has not made out a prima facie case and so far as the aspect of hardship is concerned, the Tribunal itself was conscious of the fact that on account of attachment of the bank account, the assessee was put to hardship, thus, it was directed to assessee to pay the sum in two instalments - J. DINAKARAJ V/s REGISTRAR, INCOME TAX APPELLATE TRIBUNAL - [2019] 9 ITCD Online 94 (MAD)