Well, if it something happens "DAY" and then something happens later that some day, then it makes sense to use LATER, to clarify that it's same place, just later that day (as opposed to, potentially, a mistake). But obviously, if you're reading a script and it's a particular place, day, and then the same place, and it's night -- it pretty much follows that time has passed, and using "later" would be redundant. On the other hand, obviously, if you start with a scene taking place at night, and then have another scene in the same place, later that same night -- the same rule would apply.
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