Port service classification turns on specific port authorisation, not mere licence to operate within port premises.

Terminal handling charges for container handling were not classifiable as port service for the relevant period because, under the pre-2010 definition, the service had to be rendered by a port or by a person specifically authorised by the port in relation to vessels or goods. The activities were carried out by port authorities, while the operator only arranged handling and recovered charges with a margin. A mere licence or permission to operate within port premises did not amount to port authorisation. On that basis, services performed without such authorisation fell outside port service and the demand could not be sustained on that classification.

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Issues: Whether terminal handling charges collected for container handling activities, undertaken through port authorities but without authorization from the port, were classifiable as port service for the relevant period.

Analysis: The definition of port service, as it stood prior to the 2010 amendment, required the service to be rendered by a port or by a person authorized by the port in relation to vessels or goods. The activities in question were performed by port authorities, while the appellant only arranged the handling and recovered the charges with a margin. Mere possession of a licence or permission to operate in the port area did not amount to authorization by the port for the purpose of port service. The reasoning followed the binding line of authority that, before the statutory expansion, services rendered without such authorization could not be taxed as port service.

Conclusion: The disputed activities did not fall within port service for the relevant period and the demand could not be sustained on that classification.

Ratio Decidendi: Prior to the statutory expansion of the definition, a service is taxable as port service only if it is actually rendered by the port or by a person specifically authorized by the port, and a mere licence to operate within port premises is not enough to constitute such authorization.

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