Looking more closely at the die-shots, and there is another mystery in them: The base M3 only has one display controller, despite having to support two displays (one internal + one external). Furthermore, the M3 Pro only has two controllers and can support three displays (internal + two external), and the M3 Max has four display controllers for five displays (four external + internal).
Assuming these are annotated correctly (and they might not be), it appears that some of these display controllers might in fact be able to drive more than one display, but not all of them are. It's unclear whether there are actually differences between the display controllers, or whether this is an artificial limitation.
We can't necessarily jump to conclusions that it's an artificial limitation either, since Apple still is adding one additional display controller for each additional display after the standard 2 displays (one internal + one external) from the first display controller. It's more likely that the internal display itself is driven by another separate display controller somewhere on the die that isn't annotated.