Positive portrayals can be bigoted too, especially if the conversion is to something that is just safe for the male audience, and ultimately consumption.
This doesn't mean a character can't appeal to a audience's taste, but when a strong female character is made strong but then still forced to suit the audience's tastes of femininity it would be sexist.
It's for this reason I despise the "faux action girl" trope, where a strong female character is strong on paper but it's really only to grant a token female position, mostly for fanservice. If a female character is portrayed to be competent, then they better actually be competent in practice, or it's just really a concept of making her still safe for the audience.
Sex appeal isn't inherently sexist either. For example, art in the Nanoha series often depicts Fate Testarossa as having an exceptionally notable posterior and the angles in a lot of pics would draw attention to that. However, this is just a feature of the character. It is not the character. It's ok to show characters as being sexy, but they shouldn't be used for that purpose. (Which is why the Vivid Manga is trash, since it went that way)
Now take Kaioshin's "Super flying sex doll" example. Inori's outfits, at least at the start, seems to have served no purpose rather than to flaunt her assets. Unfortunately it was to the degree where I simply wasn't even paying attention. Now, note, it's not even about how revealing an outfit is-- Fate's typical outfits are quite skimpy as well. I can't go into this without spoiling too much, but she definitely falls under the Rei Ayanami clone, in having very little or constantly changing personality. IMO, the majority of Rei Ayanami clones simply haven't worked for me simply because they try to focus on the sexuality of said characters and their seemingly indifference to it, except Rei was supposed to be creepy. It's not supposed to be moe inducing or for one to do something inappropriate later tonight for.
Overall, this is an pretty sensitive issue to me, since practically every favorite female character of me tends to be under the action girl category. I think they just stand out more in a world dominated by male protagonists. In general, for it to not reach an insulting and condescending portrayal is to have these characters do to fit the bill on paper, and also have a certain will. Essentially, they can't just spend all day doing cool stuff on screen. This is true of both males and females-- I mean sure, MD Geist is badass and all, but he's a terrible character. When I mean will, I mean they aren't just puppets meant to spread appeal to the audience. True appeal works on its own.
I would write a diatribe about each one of my favorite female characters individually but I think we're good for now-- you don't really want to scroll down for a few years, anyone?
But honestly, it seems anime handles this a bit better than say... Hollywood.