Consider:

    .PHONY: $(MAKECMDGOALS)

    qux:

    foo: qux

    bar: foo

Now make bar and make foo bar will disagree on whether foo is phony, which may or may not be what one wants depending on both what foo and qux do, and how bar depends on foo and qux side effects.

It also very much depends on what the intent is, notably such a "autophony" make foo is very different from make -B foo.