Ahhhh... I see where you're going and disagree. I think what you described is exactly what the rules are meant to allow. The "stock location" is a fixed point in space and If you have holes thru which the air was pulled originally, then you should be able to route intake tubing to/thru those holes (stock location) and then run them to a cone or panel filter. The rules states location requirements for sourcing air but doesn't state that stock compenents be used to obtain the air.

I don't see where it states that the "open intake tubing" is tied to the "anywhere in the engine compartment" verbiage and exclusionary of the "stock location" allowance.