It is when it is offered for the purposes of flattery.

[He's perfectly positioned for her to tilt her chin down and kiss his forehead, too, which she does without hesitation and only belatedly realizes that doing so inadvertently pushes his face a little too close to her throat. But, well, that was a genuine accident, so.]

For example: you are terribly handsome, and loving, and considerate, and I like to sneak peeks at your backside while you are cooking and don't know I'm looking.

[She grins at him.]

All of these things are true, but still flattery.