Its marking of the box "To be refunded" in its 2005 annual ITR constituted its exercise of the option, and from then onwards Rhombus became precluded from carrying-over the excess creditable withholding tax...
Applicability of Irrevocability Rule Under Section 76 of the Tax Code to Refund or Tax Credit Option
UPSI-MI constructively chose the option of carry-over, for which reason, the irrevocability rule forbade it to revert to its initial choice...