I think the reasons for putting an orifice type flowmeter UPSTREAM of the control valve are all of the above replies:
1)The control valve causes major dislocation in the flow profile in the pipeline, and to minimise the effects of these disturbances, a much larger straight length will be required between the valve and the flowmeter.
2) On the other hand, too much of distance between the two equipment might cause significant transportation lags to make flow control more difficult to implement.
3)the fluid downstream of the control valve might experience cavitation / flashing. Two phase flow through the orifice plate will complicate the measurement.
4)The pressure downstream of the valve will fluctuate, depending on the throttling of the valve (and the flowrate).
So, if you put the orifice plate downstream, the (upstream) pressurefor the orifice plate will vary - and so will the accuracy of the flow measurement.