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I suppose (cannot see why) that a 5.1 file that is non-Atmos will distribute sound upwards to a higher sound distribution. i.e a hard 5.1 file can only be a 5.1 sound or less. A hard 5.1 cannot move up to 7.2.4 as it does not have the information.
With the Theatre, it may be possible (I have not tried) to play a hard 5.1 file and assign the surround sides and surround backs to the same channels. i.e. a 7.1 system but sides and backs are assigned the same channel (surround sides) to become 5.1 but 4 loudspeakers play the side/back combination. This would be messy sound and ask why would you?