Does the transmission need to be dropped in order to torque down the bolts on the flywheel?

On a manual, the transmission has to be removed to do the flywheel bolts, on an auto the Torque converter bolts can be tightened via an access plate but the flex plat that is the equivalent of the manual fly wheel to the extent that the ring gear is attached, this will require the trans dropped as well, the torque converter attaches to the flex plate as the clutch attaches to the fly wheel.