Not really. They have more CUs, so more heat. They have, as far as I can tell, a _much_ smaller enclosure, so less ability to deal with extra heat.
There's less ability to deal with it at passive or nearly passive air flow levels, at any rate.
On the other hand, if the reason for the upclock was that physical characterization with the latest spins showed higher GPU clocks iso-power, Orbis could see *some* benefit if it's in terms of process improvement and the two chips also share the same fab.
The larger amount of active logic in the Orbis GPU may pose a chance of increased variation and the benefits to logic and SRAM may not be proportionate, so it may not be equivalent.
For the sake of argument, let's assume the Durango APU is 100W, of which the Jaguar cores are between 1/4 to 1/3 the TDP.
Assuming Durango isn't operating at the edge of needing a voltage bump, the power increase should be linear at this small increment. That's .07 percent of 66-75 Watts, or around 5 Watts.
Orbis, with 1.5x the CU complement would pull up to 8W more, assuming it isn't riding the edge of some voltage bump. I'm handwaving whether 32MB of faster SRAM or 16 extra ROPS add more to either side of the equation.
This bump should only matter at load, given the granularity of AMD's current GPU power management. As far as getting heat out of the enclosure, isn't it conceivable that Sony had a guard band of 5-10 Watts, or had the option to bump up the RPMs of the fan by an increment just in case?