Prism Corp., a VAT-registered domestic corporation engaged exclusively in zero-rated transactions under Section 108(B) of the NIRC, accumulated excess input VAT for the third quarter of 2024 (July 1–September 30, 2024) amounting to ₱4,500,000. On January 10, 2025, Prism Corp. filed an administrative claim for refund of excess input VAT with the Bureau of Internal Revenue. The BIR did not act on the claim within the prescribed processing period. On April 30, 2025, Prism Corp. filed a Petition for Review before the Court of Tax Appeals (CTA) First Division. The BIR moved to dismiss the Petition on two grounds: (a) the judicial claim was filed prematurely because the BIR has not yet resolved the administrative claim; and (b) the two-year period for filing a claim for refund under the NIRC has not elapsed, so the CTA has no jurisdiction. Should the CTA grant the BIR's motion to dismiss? Explain.