I think this is one of those areas where judgement is needed. If a player swings his elbows, with no chance of connecting with a player, how can you call a T? This would be like a player getting ejected for shadow boxing on court. Sure throwing a punch is a toss, but only if it aimed at, or has the possibility of connecting with, someone.
My ruling: Good Call! Warn the player and get on with the game.
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