Currently upsert will always create new entities if you supply the required fields (in lots of our tables only an id is needed and nothing more).
It would be nice if we could supply additional headers (or a flag) for the
If-Match: * header (or the If-None-Match: * but then you could also use create) to limit this cf. https://learn.microsoft.com/en-us/power-apps/developer/data-platform/use-upsert-insert-update-record?tabs=webapi