https://drafts.csswg.org/cssom-view-1/#propdef-scroll-behavior
I looked through issues here as well as the www-style mailing list to see any discussion around why this scroll-behavior has this caveat...
The scroll-behavior property of the HTML body element is not propagated to the viewport.
I couldn't find anything. If the body element does not have a scrolling mechanism why can't scroll-behavior propagate to the viewport?
Currently there is an open issue for chrome regarding the properties implementation, with an example that sets the property to smooth the body element and of course it doesn't scroll the viewport smoothly, per spec, but if you try that example in firefox, they in fact do allow propagation.