I have tested with this option $config['checkVersion'] = false; and still receive upgrade a message. Also the form in tools/upgrade-check still process without error.
That configuration setting prevents the forum from displaying a pending upgrade message when the files have been uploaded but the upgrade has not yet been run. It doesn't prevent upgrade checks from running.
Yeah that’s really not the purpose of that config value.
It’s nothing to do with one click upgrades. It suppresses the message (and bypasses a few restrictions) when the version in XF.php is newer than the database version.