I think I need to explain the problem I’m talking about in more detail.
Of course, there are good and bad mixes. Still, the problem I'm talking about is Atmos mixes where I believe an instrument was meant to be panned somewhere to the outside of the front speakers, but still be kept in the front ”hemisphere” just for widening the stereo field, while still keeping the instrument somewhat in front of the listener. The volume balance between the front speaker and the surround speaker, which needs to share the job of positioning the instrument as a phantom sound in that position, will be highly critical. If the volume balance between the front speaker and the surround speaker is different between the system used for making the mix and the playback system at the home of the consumer, the position of the instrument will change.
In my surround system, I find most Atmos mixes sound as I would expect them to sound, with the main instruments positioned somewhere in front of me as a listener. But once in a while, the guitar in a rock mix is not only hard panned to one of the front speakers in a typical rock mix fashion, but also panned to the surround speaker to make the mix even larger/wider. And that's all fine, but it gets really strange when the sound of the guitar is a little louder in the surround speaker compared to the front speaker, as that makes the instrument appear to be slightly behind the plane of the listening position. That is something I doubt was the intention of the person making the mix.
I can buy the idea of going extreme and panning the guitars straight to the sides of the listener, but not behind, and when that happens, I'm quite sure the surround speakers at the mixing studio were playing quieter than they should have, making the mixing engineer overcompensate the loudness level in the surround channels.