That's exactly why it keeps coming up. It's easy to grow 50% when you're making a relatively small number of items, it's another thing entirely when you're much larger. So for Tesla to post these growth figures is meaningless without taking the actual numbers of cars shipped into account.
I don't think the apples to oranges comparison helps make the point anyway. It's just a throw-away. If someone writes "Toyota makes 9MM cars", I discard as "wrong thread". Even if the difficulty curve changes shape against Tesla starting right now, Toyota's production capacity remains pretty irrelevant.