Kalayaan Textile Corp. (KTC), a VAT-registered domestic manufacturer, sells finished textile goods exclusively to Sunrise Electronics Corp. (SEC), a PEZA-registered enterprise operating inside the Laguna Technopark Special Economic Zone. In 2024, KTC treated all its sales to SEC as VAT zero-rated under the cross-border doctrine and claimed a refund of its accumulated input VAT amounting to ₱1,800,000. The BIR denied both the zero-rating treatment and the refund claim, arguing that the goods were physically delivered within Philippine territory and therefore cannot be considered "exported." Is the BIR correct?