12 month cooling off period

[monu1234]

Hello,

Below are details of my COS and VISA that expired lately:-

COS start date 22-Jan-2010 & end date 22-jan-2012
Visa start date 22-jan-2010 & Visa expiry 22-jan-2012

I last visited UK for period 1 July 2011 to 31 sep 2011.

Now my cmpny is again looking to apply my COS under ICT Tier2 application, as i am not sure if cooling off period applies to me , can you please help me?

1) Does cooling off period apply to me as my COS was applied before 6 april 2011/12?
2) If cooling off period applies to me then is it from my last day in UK i.e. 31 sep 2011 i or from my VISA expiry date i.e. 22-jan-2012or else my COS expiry date i.e. 22-jan-2012?

Also just to let you know that i am not eligible for long term category as my salary is less then 40K

Thanks,

[monu1234]

Please help!!!