You can always clean-install a new iOS update in DFU mode, and in this use case the iPhone isn't configured so preserving any non-existent data isn't necessary. But it also looks like you can always update with data through DFU mode?[1] It doesn't say whether the computer has to be pre-authorized with that iPhone, but it's also DFU mode where authorization matters less, so shrug.

1: https://support.apple.com/en-us/HT201263