you have to remember if you place it on its side and everything is stationary then the oil will find its way through the small gap in the seal ring, if the turbo is horizonal like normal and spinning then its harder to find the gap and seep out. only other way out then is past the actual outer edges of the turbo seal itself which means the seal isn't doing its job and wants replacing.
This is also why garrett for example don't recommend fitting a turbocharger past 10' maximum of horizonal plane.
Tim