Accident-linked insurance proceeds payable on death are excluded from estate duty when no lifetime beneficial interest exists.

Accident-linked insurance proceeds payable only on the insured's death, where the deceased had no beneficial interest during lifetime, are not property passing on death for estate duty purposes. The Tribunal held that amounts received under a group term insurance policy, group personal accident insurance policy, and double accident benefit were outside the principal value of the estate because they accrued to the legal heirs by operation of the policy terms and nomination, not from any interest ceasing on death. Applying the Estate Duty Act principle on property passing on death, the amounts were excluded from the estate.

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Issues: Whether amounts received under a group term insurance policy, group personal accident insurance policy, and double accident benefit were includible in the principal value of the estate for estate duty purposes.

Analysis: The amounts were payable only on death by accident and the deceased had no beneficial interest in the policies during his lifetime. The legal heirs received the amounts by virtue of the policy terms and nomination, and not as property passing from the deceased on death. Section 6 of the Estate Duty Act, 1953 applies only to property passing on death or interest ceasing on death, which was not attracted here. The issue was covered by the Supreme Court ruling relied upon by the Tribunal, and the Board's circulars also supported exclusion of such amounts from the estate.

Conclusion: The amounts of Rs. 1 lakh, Rs. 1,74,600, and Rs. 85,000 were not includible in the estate and were liable to be excluded. The issue is decided in favour of the assessee.

Ratio Decidendi: Amounts payable under accident-linked insurance benefits, which accrue only on the death of the insured and in which the deceased had no enforceable lifetime interest, do not constitute property passing on death or interest ceasing on death under estate duty law.

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