10.119.—(1) The court may make the order applied for, with any modifications which appear appropriate, having regard to any representations made on behalf of the Commissioners.
(2) The order—
(a)may be addressed to an official of Her Majesty’s Revenue and Customs other than the one named in the application;
(b)must specify a time, not less than 28 days after service on the official to whom the order is addressed, within which compliance is required; and
(c)may include requirements as to the manner in which documents to which the order relates are to be produced.
(3) A sealed copy of the order must be served by the applicant on the official to whom it is addressed.
(4) If the official is unable to comply with the order because the relevant documents are not in the possession of the official, and the official has been unable to obtain possession of them, the official must file with the court a statement as to the reasons for the official’s non-compliance.
(5) The official must deliver a copy of the statement referred to in paragraph (4) to the applicant as soon as reasonably practicable.