From my father's experience as property damage appraiser, automatic transmissions heating up enough to ignite the transmission fluid were a fairly common failure mode for towing with wheels down. They could also explode violently enough to throw shrapnel through the firewall or floorpan.
"Safe to tow" is not an absolute, it is relative and probabilistic. The transmission doesn't have to have slipped into gear for a failure like this, it can be just that it was not well enough lubricated to handle the heat generated by towing speed and time. Everything has to go just right, and there are some little things that can go wrong. This is why manufacturers who say "OK" change their recommendations after experience gives them a failure rate they find unacceptable.