BIR ITAD and refunds on erroneously paid taxes

It is a well-settled principle that tax exemptions are construed strictly against taxpayers. Hence, tax refunds, which are considered as tax exemptions, are resolved strictly against the claimant.
Under Section 229 of the Tax Code of 1997, as amended, any national internal revenue tax alleged to have been erroneously or illegally assessed or collected may be refunded within two years from the date of payment of the tax or penalty by filing a claim for refund or credit with the Commissioner of Internal Revenue (CIR).