penalty of 3b

A person has just got reg. 4-5days ago. In reg. The date of commencing business is 20 aug. he has not filed 3b yet. There is no c/f credit i..e. not covered in tran 1 . there is nil t/o . So my question is whether penalty of rs.100 will be attracted. If yes what is the remedy to avoid it. He is in business of air/rail booking agent