or it could be that both are true.
in a vertical environment, like a Warre, which is supposed to mimic bee life in a vertical tree, the bees start building comb at the top of the void and the queen lays eggs in the comb as it is drawn, initially, near the top. As the comb expands downward in said vertical environment, the queen will begin to move downward to lay eggs and the bees will be gin to backfill the upper cells with honey and pollen.
in a horizontal environment, such as a ktbh, which is supposed to mimic a horizontal log or floorboard/ceiling type of nest, the bees will begin to draw comb somewhat near the entrance, not always immediately near it, and the queen will lay in those cells. As they build comb to fill the void between the started comb and the entrance the queen will move toward that comb to lay new eggs and the bees will begin to backfill the previous comb with honey, typically keeping the queen confined to the first 8 or 10 or however many combs lay in between the entrance and the furthest comb she can lay eggs in that aren't backfilled.. As the bees look for places to put nectar and pollen, the first combs are full of brood and eggs and so they build comb beyond the original comb, now the backfilled honey comb, to store more honey.
At least, that's how I've seen it work in my tbh's and Warres. plus the cutouts I've done.
but, that could just be me.
enjoy the bees.