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It's not about how we consider what is to be tsundere, but we're debating weather Kyou is acting tsun or friendly.
Every single person out there does show manners of dislike to another person they dislike, and vice versa for those they like, but you don't call everybody a 'tsundere' right? When talking about tsun and dere, they have to be acting towards the same person. Kyou has never, ever acted tsun towards Tomoya and dere towards Sunohara (apart from the final choice in her route). Therefore, Kyou is consistent in terms of mood. And thus, Kyou is not a tsundere because she doesn't exhibit the triats of a tsundere where they have a mood swing between 'tsun' and 'dere' towards one single character.
On the contary, if we use your theory that Kyou is tsundere because she acts 'tsun' towards Sunohara and 'dere' towards Tomoya, then we can have to be consistent and see that Nagisa is a tsundere because she is always ignoring Sunohara and paying attention to Tomoya, but now you say she is not a tsundere--how can you justify that then?
(Note: I do not think Nagisa is a tsundere because she is consistent in her mood.)
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