No, I really can't see what you are suggesting other than some personal reason for booking IFR time....
I have never taught VFR skills under IFR in over 2,000hrs of teaching and testing. The training side of our operation in Spain operates in CAS and we do not file IFR flight plans for VFR training. Our ops manual clear states that where conditions require compliance with IFR then training is not permitted for VFR courses. I also do not accept time logged on VFR courses as IFR towards the Instrument Instruction pre requisites....
We have very clearly stated VFR minima and its not permitted to circumvent them by filing IFR.
I also fully understand the need to differentiate between flight under IFR and and flight in IMC and don't seem to recall talking about flight in IMC.
