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Facts: Zenith Holdings, Inc., a domestic corporation, was assessed deficiency corporate income tax for 2019 by the BIR after the disallowance of foreign tax credits on royalty income received from a foreign affiliate. The Court of Tax Appeals (CTA) ruled in favor of the BIR. Zenith filed a Petition for Review on Certiorari with the Court of Appeals alleging grave abuse of discretion amounting to lack or excess of jurisdiction in the CTA decision. The Court of Appeals denied the petition. Zenith then filed a Petition for Review on Certiorari with the Supreme Court, contending that the Court of Appeals gravely abused its discretion by misapplying foreign tax credit provisions and the source-of-income doctrine. Questions: (a) Identify the controlling doctrine governing petitions for review on certiorari in tax matters and the standard the Supreme Court applies when reviewing Court of Appeals decisions. (b) Distinguish the controlling rule from other available remedies by clarifying the scope of review and the treatment of findings of fact versus questions of law. (c) Apply to the facts: given that the Court of Appeals purportedly misinterpreted the foreign tax credit provisions and the source-of-income doctrine, does the petition present a proper question of law and a valid demonstration of grave abuse such that the Supreme Court should grant the petition for review on certiorari?