Under CREATE MORE, when can a taxpayer-applicant for input VAT refund, who is unsuccessful at the administrative, file a petition for review before the Court of Tax Appeals? * Under the CREATE MORE, if a taxpayer for input VAT refund becomes unsuccessful at the administrative level, he must file a motion for reconsideration to the Bureau of Internal Revenue prior to filing a Petition for review before the Court of Tax Appeals to observe the proper observation on the principle exhausting of the administrative remedies at the lower level