Commencement of operation

Yes, Section 11(1) clearly provides for 'filing' of declaration and not its 'approval'.  

But a problem may arise in a hypothetical case where the ROC asks for some additional information and company  fails to provide the same to the satisfaction  of ROC within the prescribed time.  In such a  case the form can be rejected and treated as not filed.  Hence one prefers to wait for its approval.  Of course, chance of such case is remote.