On July 15, 2023, Dagitab Energy Corporation (DEC), a VAT-registered entity engaged in the sale of electricity, filed with the Bureau of Internal Revenue (BIR) an administrative claim for refund of unutilized input VAT attributable to its VAT zero-rated sales for the second quarter (April to June 2022) in the amount of ₱6,800,000. On October 20, 2023, without waiting for the BIR to act on the administrative claim, DEC filed a Petition for Review before the Court of Tax Appeals (CTA). The BIR opposed the petition arguing: (a) the administrative claim was filed out of time, having been filed more than two years from the close of the taxable quarter; and (b) the judicial claim was prematurely filed because the BIR had not yet rendered a decision on the administrative claim. Rule on both objections. Explain your answer. (Bar 2026 Syllabus)