Since you used the word subpanel, this leads me to believe that you aren't talking about a "hot bus" MLO main panel.
If there is any OCPD on the line side of the main lugs, then that acts as the main breaker as far as 705.12 and the 120% rule is concerned. The 705.12 article refers to the "overcurrent device protecting the busbar", which doesn't only mean an internal main breaker. It could be a branch breaker acting as a main, or an externalized OCPD. Such as a fused disconnect, a breaker in a meter/main combo, or a breaker from a higher ranking panel supplying the subpanel.
The reason why you need the breaker on the opposite end of the main supply to take credit for the 120% rule, is that Kirchhoff's current rule makes current subtractive at the busbar cross sections, rather than additive, when you feed the panel from opposite ends. Feed from the same end, and the current is additive. Panels are routinely populated with more load breakers than the main supply, on the underlying assumption that they won't all draw their full load at once, and the main breaker will ultimately protect the panel before it overheats. Adding a PV interconnection, allows for an overload to be in the blind spot of the main breaker.
Without putting the interconnecting breaker at the opposite end, the 120% rule becomes a 100% rule instead.