Dave,
Point take on the CFIT definition. However, you need consider USOS definition...….my bolding.
An undershoot/overshoot of a runway/helipad/helideck
occurs in close proximity to the runway/helipad/helideck
and includes offside touchdowns and
any occurrence in which the landing gear touches off the runway/helipad/helideck
surface.
I'm sticking with this being CFIT, as the touchdown was not really
in close proximity to the runway - it was close, but I don't really think this event fits with the USOS definition. And because USOS is accepted to be in close proximity to the runway, that's why you don't use CFIT in that instancxe as you correctly point out.
CVR will obviously shed light on what was/wasn't happening immediately before the touchdown, and will probably clarify if it was CFIT or USOS.
Happy to be wrong on this though Dave...