Drain connection on toilet trap arm?

[Plumbob401k]

So my question is can you connect right under the toilet flange I mean they do sell sideheel outlet bends but can you do this
Or we follow chapter 10. 1001.1 on the UPC code book and no drain connections before vent thanks my fellow plumbing bros
And Terry for this awesome website

 

[Terry]

What is going into it?
If it's a vented fixture like a lav, shower or tub then no problem. It would be a bathroom fixture wet vent.
If it's a washer or kitchen sink, (non bathroom fixture) then it would need to come in after the vent.