Why would he, and how could he? I would have asked/fought this one before changing it. Frankly, I am sick and tired of Inspectors who attempt to enforce non-existant codes from faulty memories of what they might have thought it said, and call it gospel. Without siting a code or other reason... Sometimes it is nessesary to advocate for yourself and your customer against these types, and pull out a book and make them find it. Granted what it says is subject to THEIR interpetation, but they have a harder time pulling it out of their wazzoo if it is just not there, and you get the opprotunity to either learn or debate if it is.
410.31, and 410.32 cover this situation, (as raceways) but 'georgestolz' nailed right off - they were not used as raceways, they were used as 'junction boxes' with feed 'through wiring'... 410.10 & 410.11 And odds are that the fixture described is rated/listed for all of the above situations. (Other types my not be, but very doubtful in a 2X4 troffer.)