A flashback in the middle of an action scene can slow things down and annoy the reader. However, after an action scene, during the recovery scene, a flashback can help develop character and plot. For example, you have a scene where the character fights a man and notices he has a strange tattoo. After the man gets away, there is a flashback to when the character witnessed a man with that tattoo killing someone. The flashback isn't during the action scene, but during the recovery scene.