The Commissioners may, as a condition of allowing or repaying any input tax to any person, require the production of such documents relating to VAT as may have been supplied to him and may, if they think it necessary for the protection of the revenue, require, as a condition of making any VAT credit, the giving of such security for the amount of the payment as appears to them appropriate.

Without prejudice to their power under section 48(7), where it appears to the Commissioners requisite to do so for the protection of the revenue they may require a taxable person, as a condition of his supplying goods or services under a taxable supply, to give security, or further security, of such amount and in such manner as they may determine, for the payment of any VAT which is or may become due from him.