Estate duty attaches to the death of the beneficial owner of benami property, not to the ostensible owner. Liability for estate duty in respect of property held benami arises on the death of the real (beneficial) owner, since the beneficial owner holds the true title and the benamidar is merely an ostensible owner with no proprietary interest; inability to recover property from a purchaser lacking notice does not confer real title on the benamidar, so assessment under the Estate Duty Act proceeds on the basis of the beneficial owner's death and title.