The book, Analysis of Changes 2020 NEC has an interesting writeup on 408.43. It says that the intention of "face-up" is that the enclosed OCPD are facing upward. So 408.43 would allow a panelboard to be mounted face-down, but still horizontal. But it still seems like the two sections are opposing.
240.33: Enclosures for overcurrent devices shall be mounted in a vertical position. Circuit breaker enclosures shall be permitted to be installed horizontally where the circuit breaker is installed in accordance with 240.81.
408.43: Panelboards shall not be installed in the face-up position.
Circuit breaker enclosure is not defined in the NEC. So is the provision in 240.33 limited to circuit breaker enclosures that are not panelboards and what is a circuit breaker enclosure then? Does 240.33 have the be interpreted to mean circuit breaker enclosures can be mounted horizontally but not face-up?