Dismissing the appeal the Court held that  except raising a bald allegation that the property had been excessively valued than the prevailing at the time of execution of gift deed, hardly any material much less substantial material was placed before the authorities under the Act, at least to canvass the ground in the court that the finding of fact was recorded without considering the material on record. The assessee or her legal heir was now contesting the ownership of the property. The burden was on the assessee or her legal heir to prove that the ownership of the property vested with someone else, not the assessee. The entries in the revenue records, or the name of the assessee in Municipal Corporation, were not conclusive as regards the ownership of the property. The Tribunal, therefore, rightly observed that the assessee failed to place contra evidence on the ownership of the property.