Date of setup of business is different fom date of commencement of business

It is held in recent case of Reliance Jewels & Gems Ltd Vs DCIT (Mumbai ITAT) that even though business has not commenced, still it can be considered to be 'set-up' i.e. ready to commence its business operations. It is not a pre-condition that the business should actually be running. 
The Department had contended that mere hiring of employees does not amount to business being set-up. The ITAT held otherwise.