Horizon Corp., a domestic corporation, filed its Annual Income Tax Return for taxable year 2018 on April 15, 2019, declaring gross income of ₱10,000,000 and net taxable income of ₱500,000. In May 2024, a BIR audit revealed that Horizon Corp. had intentionally failed to declare rental income amounting to ₱3,000,000, which was routed through an undisclosed bank account. The undeclared income represented thirty percent (30%) of the declared gross income. The BIR issued a Preliminary Assessment Notice (PAN) in June 2024 and a Final Assessment Notice (FAN) in August 2024, both for deficiency income tax for taxable year 2018. Horizon Corp. argues that the BIR's right to assess has prescribed, as more than three years have elapsed since the filing of the TY 2018 return on April 15, 2019. Is Horizon Corp. correct? Explain.