Sponsorship Rejection - Cooling off period

We applied for a Tier 2 sponsorship licence in October 2014 and it was rejected because of a problem with the labour market test.

We redid the labour market test and submitted a new application in December 2014. This time we received a rejection letter advising that we can only re-apply after the 6 months cooling off period.

According to the immigration consultant we used, the cooling off period will be after the last rejection letter, but I studied the HO guidance notes and it looks like this is not the case - it will be based on the 1st rejection. The 2nd letter was just to remind us of the cooling off period and that we applied too soon, hence the rejection.

I even phoned the HO and the helpful lady on the phone actually confirmed this, albeit with some hesitation - hence my post.

Does the cooling off period starts after the 1st rejection letter, or does it reset every time you submit an application that is unsuccessful?