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NovaGen, Inc., a corporation subject to corporate income tax, receives a deficiency assessment for 2023 from the Bureau of Internal Revenue (BIR). NovaGen timely files a protest with the BIR, which the BIR denies in writing. Instead of filing a petition for review with the Court of Tax Appeals (CTA), NovaGen directly files a petition for certiorari with the Supreme Court challenging the denial on the ground of grave abuse in processing the protest. The Supreme Court dismisses for lack of jurisdiction. (a) Identify the controlling doctrine governing judicial remedies in tax disputes under the NIRC. (b) Distinguish the proper forum and the nature of the remedy from direct recourse to the Supreme Court. (c) Apply the doctrine to the facts and determine the proper course of action and likely outcome given the present procedural posture.