Circular Analysis of Economy Minister with No. 249931- 1396/11/4; Challenge from the perspective of Extraordinary Tax Hearing

In modern law, procedure is important; in such a way that it is impossible to explore aspects of a country's law. In repeated article 251 of the Direct Tax Act forecasted If the taxpayer for any reason complains of the designated tax and not be able to file a complaint with any authority it can sue the Minister of Economy by providing evidence. In this respect, the subject of this article is "extraordinary tax proceedings"; Without any special provision in this article. In this regard, in 1396 the circular was issued and based on that, Taxpayers can Complain about their complaint within the framework of the procedure provided for in that document. This article understands the importance and position of this executive document the answer to this question is: from the perspective of extraordinary tax hearing, what are the damages to the Minister of Economy's 1396 Regulations? In answer to this question, using a descriptive-analytical method, the following conclusions are drawn: First, the aforementioned circular failed to satisfy the requirements of extraordinary jurisdiction. Second, the document has raised some kind of bureaucracy and cost to the government. Third , the document marginalizes the existential philosophy of the repeated article 251.