XX. Krisp Kleen, Inc. (KKI) is a corporation engaged in the manufacturing and processing of steel and its by-products. It is both registered with the Board of Investments with a pioneer status, and with the BIR as a VAT entity. On October 10, 2010, it filed a claim for refund/credit of input VAT for the period January 1 to March 31, 2009 before the Commissioner of Internal Revenue (CIR). On February 1, 2011, as the CIR had not yet made any ruling on its claim for refund/credit, KKI, fearful that its period to appeal to the courts might prescribe, filed an appeal with the Court of Tax Appeals (CTA).