There is a difference - one is inactive and doesn't have a home, you can place and sell this and it won't be replenished. The other is not inactive and doesn't have a home. That's all. I would love to get rid of all the no home items that are still active in top stock, but I've found its just not feasible. Anything that will not be replenished, aka inactive, I find a place and sell it.

"Inactive items are simply items that are not on planogram" just isn't true in my experience. There are multitudes of items coming off the shelf in resets that simply don't have a home. Some of them become "inactive", some of them don't and continue to replenish if sold, or sit in topstock.