Reading the article, it seems to boil down to the following two observations:
1. ARM64 is actually less "smart" than x64. While Intel's Core i9 tries to be clever by aggressive boosting and throttling, Snapdragon just delivers steady and consistent performance. This lack of variability makes it easier for the OS to schedule tasks.
2. It is possible that the ARM build is more efficient than the x64 build, because Windows has less historical clutter on ARM than x64.
So, has CPU throttling become too smart to the point it hurts?