Suspension of tax collection during MAP allows abeyance of tax demands upon furnishing an irrevocable bank guarantee pending bilateral resolution. A bilateral MoU permits suspension of enforcement of outstanding tax demands during MAP on confirmation of pendency and subject to the taxpayer furnishing an irrevocable bank guarantee covering disputed tax and interest. The Assessing Officer shall keep collection in abeyance for an initial two year period, extendable by mutual agreement of the Competent Authorities up to an aggregate cap, and may resume recovery or invoke the bank guarantee only after receiving appropriate notification regarding MAP resolution or expiry of authorised suspension.