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	GR No. 171742 2011-06-15	CIR v. MIRANT MENDOZA, J.
In Commissioner of Internal Revenue v. Far East Bank & Trust Company (now Bank of the Philippine Islands), [33] the Court enumerated the requisites for claiming a tax credit or a refund of creditable withholding tax: 1) The claim must be filed with the CIR within the two-year period from the date of payment of the tax;