I am still skeptical, there are a couple of reasons that I think it might not pre-date the Edo period.
I think your dating is rather optimistic, looking at extant examples, we do not start seeing defined Seppa-dai until the late Muromachi period, and they only become common place from the Momoyama period onward. While the shape of Hitsu-ana can be useful in determining relative age, there are many variables at play, particularly with an oval shaped example, which could have been reshaped and adjusted many times. If the Hitsu-ana is indeed cast into the design, that would also generally indicate later dating.
Concerning the motif, while animal and creature motifs are not uncommon, the way the dragon has been rendered does not align with any other examples I have seen, I also still do not think that the way the design is rendered aligns with Sasano's #10, but perhaps some additional photos from different angles might help with this. The shape being being Kaku-gata is interesting, not something typically seen with Kagami-shi, but something that is common in Namban style Tsuba, as are squarish Seppa-dai and and flat faced rims.
Cast bronze Tsuba were definitely produced in the Edo period, they are usually pretty easy to spot because they follow Edo period trends and styles, some Namban Tsuba were also cast in bronze.
The dates for Tsuba of this type are all over the place, there is a lot of "vibes" based dating for early Tsuba in general, not just in the Kagamishi book and Tosogu no Kigen, but many other publications. There is very little evidence to support how the date attributions are made. We are all guilty of accepting these at face value and a lot more research needs to be done in this area.