If you want to lyse the cell later, it should be fine for 24 hours. But if you want to keep the cell viable, then it is not suitable to store it under -20
if you want to keep your protein safe without degradation then keep your cells at 20 for about a month (we have already tried, loss of protein in our case is in significant). if you want to keep cells viable then you have to store them under -80.
If you have kept cell pellet without any cryo-protectant, then cell will not be viable any more.
If you want to use cell pellet (without any cryo-protectant,) further, it will be nice to keep them at -80 for long term usage. If you want to use them within 15 day then -20 will be OK.