Fair, but my comment was about the rumored M3 Max beginning to prioritize performance over power efficiency. The M2/M1 Max and Pro have the same CPU configuration so unless you are utilizing the GPU the peformance & power draw is very similar.
I think the M3 Max (assuming the rumors are correct) will still be a great portable system but there may be a bigger difference between the Max and Pro for battery life.
This is highly unlikely in the general case.
What I mean by that is, for a given workload, the M3 Max will not be less efficient than the M3 Pro (or M2 Max, for that matter). If the M3 Max can run at higher clocks than the Pro, it will still be able to run at lower clocks as well. And if it does indeed have more cores than the Pro, it will be able to deep sleep or totally shut down cores that aren't in use.
If you have a workload that crushes an M3 Pro, then the M3 Max may draw more power to handle it. But it will still be at least as efficient (possibly more efficient if it benefits from race-to-idle). The only exception to this will be whatever "high power mode" it may support, but that will be at the user's option (and probably only when plugged in).
Thus for normal workloads, you'll see the M3 Max battery life be superior to the M2 Max, wh for wh, and likely no more worse than the M3 Pro's than the M2 Max is worse than the M2 Pro (which, IIRC, is not too much, and likely attributable mostly to other hardware like the screen). Of course, if you run a power virus, you'll be able to drain the battery faster on the Max than the Pro, because you'll have more cores available to suck the power down.
...or, wait, no, not even then. If you have only N watts to spread among your cores (which is true - you're limited by cooling), for any large workload that isn't bound by single-threaded performance, you will probably do better with more cores than with fewer. That is, if you can run either 8 P cores or 12, you're always going to do better with 12 (assuming you can fill all 12 with work). That's because if you divide your N watts among 12 cores instead of 8, you'll have to give each of them 33% less power, but (since power consumption correlates with the *square* of the clockspeed) the clock on each core will go down by a lot less than 33%. That will get you a net performance gain for the same amount of power used.
If you think about it, this is just another iteration of the same argument that Apple followed in building their cores all along: wide > high clocks.