In theory they could apply the gyroscope based movement to Dolby Atmos based music as well. But who wants to turn 90 degrees left and have the songs soundstage not also shift with them?
Apple TV doesn’t have Spacial Audio. Only iPads and iPhones.
Apple TV the streaming service. Not Apple TV the hardware or Apple TV the app or any other Apple TV that apple makes.
The streaming service is Apple TV+ while the App is TV and the device is called Apple TV.