Facts
[A. AG] , domiciled in [U.] /CustA, was limited tax-liable in the canton of Graubünden during the 2019 tax period due to a property in [V.] /GR, which it sold on 16 November 2018. As the company had not submitted its tax return despite a reminder, the canton of Graubünden assessed the cantonal and municipal taxes 2019 for [A. AG] based on discretionary assessment. [A. AG] filed an objection against this discretionary assessment, which the tax administration did not consider, as the company had not provided evidence of the obvious incorrectness of the assessment. The Administrative Court of the canton of Graubünden partially upheld the appeal of [A. AG] and referred the matter back to the tax administration for a substantive assessment. [A. AG] appealed against this decision to the Federal Supreme Court.Considerations
The Federal Supreme Court dismisses the appeal. It considers it permissible that the lower instance, despite the tax administration's non-consideration of the objection, has carried out a substantive assessment, as the tax administration had made such an alternative assessment in the objection decision. Regarding the substantive assessment, the Federal Supreme Court concludes that [A. AG] has not provided evidence of the obvious…