Consequences of late filing of 23b

Hello,

AGM of a pvt ltd company was held on 8th Sept 2011. Now a new CA was appointed and he was intimated by the company on 11th Sept 2011. The CA has not yet informed the Registrar through Form 23B. I know that there is no fee for this form. But what are the consequences if the CA files this form in January? Is there some penalty or some other violation which he has to deal with? Or is this dealt with liberally by the Registrar?