226/-. While doing so, the AO disallowed the loss on account of foreign currency transaction of Rs. 21,84,084/-. The said assessment order attained finality as the appellant had chosen not to contest further. The AO had initiated penalty proceedings u/s. 274 r.w.s. 271(1)(c) of the Act vide show cause notice dated 30.12.2019 for furnishing inaccurate particulars