The emergence of In-Context Learning (ICL) in LLMs remains a significant phenomenon with little understanding. To explain ICL, recent studies try to shed light on ICL by connecting it to Gradient Descent (GD). However, the question is, do these hold up in practice in actual pre-trained models? We highlight the limiting assumptions in prior works that make their context considerably different from the practical context in which language models are trained. For example, the theoretical hand-constructed weights used in these studies have properties that don't match those of real LLMs. Furthermore, their experimental verification uses ICL objective (training models explicitly for ICL), which differs from the emergent ICL in the wild. We also look for evidence in real models. We observe that ICL and GD have different sensitivity to the order in which they observe demonstrations. Finally, we probe and compare the ICL vs. GD hypothesis in a natural setting. We conduct comprehensive empirical analyses on language models pre-trained on natural data (LLaMa-7B). Our comparisons of three performance metrics highlight the inconsistent behavior of ICL and GD as a function of various factors such as datasets, models, and the number of demonstrations. We observe that ICL and GD modify the output distribution of language models differently. These results indicate that the equivalence between ICL and GD remains an open hypothesis and calls for further studies.