Broad port service definition brings authorised vessel repair work within service tax net.

The definition of "port service" under the Finance Act, 1994 was applied broadly to cover services rendered by a person authorised by port authorities in relation to vessels or goods, including repair work on vessels. The expressions "in any manner" and "in relation to" were treated as expansive, and the statute was read as not limiting authorisation to functions exclusively required to be performed by the port. On that basis, ship chandlers undertaking vessel repairs and acting under port authorisation were liable to registration and service tax as providers of port service, and the tax demand was sustained on this issue.

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Issues: Whether ship chandlers who undertake repair work on vessels and are authorized by the port authorities render taxable "port service" under the Finance Act, 1994.

Analysis: The definition of "port service" was held to be wide, covering any service rendered by a port or any person authorized by it, in any manner, in relation to a vessel or goods. The expressions "in any manner" and "in relation to" were treated as expansive, and repair work on vessels was found to fall within that broad language. The contention that authorization must be confined only to functions exclusively required to be performed by the port was rejected, since the statute does not draw such a distinction between authorization and delegation.

Conclusion: Ship chandlers who perform repair work on vessels and are authorized by the port authorities are liable to registration and service tax as providers of port service, and the challenge to the demand failed on this issue.

Ratio Decidendi: Where a statute defines a taxable service in broad terms as service rendered by an authorized person in relation to a vessel, repair activities on the vessel fall within the tax net and authorization need not be confined to functions exclusively required to be performed by the port.

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