I don't agree. If you tap a busbar with a lower ampacity conductor then 240.21(B) are the rules that apply to the conductors. And the NEC definition of a feeder isn't specific enough to exclude a switchboard busbar, nor does that have any bearing on the application of 240.21(B). But the manufacturer tells you how you can terminate conductors to components in a switch board, and whatever that method is, it has to be okay with the engineering and product standard. And drilling holes in busbars without any instructions certainly isn't okay, right? You need holes marked 'Tap', or unused lugs, or else probably a UL field listing that satisfies the AHJ...we know the drill (so to speak). The violation is 110.3(B), unless you can work out a way that it's not a violation.
As far as line vs. load, again, 'people' getting all 'tap happy' on listed equipment presents the same issues, line or load side, as far as I can see.