The empirical studies are fairly weak as well – none of them suggest that there is actually any gradient descent occurring during in-context learning, only that if you fine-tune a model's attention parameters (and no other parameters) for a set of examples, its internal representations and attention patterns are slightly more similar (and it's really not by much!) to those of in-context learning than before fine-tuning. Is it really that surprising? You could most likely take any two techniques that optimize a model towards some target, artificial restrict both of them to only apply to the same set of parameters, use both, and find increased similarity of the two optimized models compared to the non-optimized model.
None of that would be what the paper claims, i.e., a shared mechanism of gradient descent, just a similarity in outcome – and we all already knew that ICL and fine-tuning have similar results!