Same settings, same channels, and one account comments happily while another keeps hitting limits. Identical accounts do not exist — here is what differs.
Age and dormancy
An account registered six months ago and left quiet carries credit. A fresh one does not. The same workload is a different workload from Telegram's point of view.
Action history
An account with subscriptions, conversations and ordinary activity looks alive. One that started commenting straight after registration does not. That difference is invisible in any interface and it sets the thresholds.
Number reputation
Numbers are sold in batches and have often been used before. If the previous account on that number attracted complaints, the new one inherits part of the suspicion — which is why accounts from one batch behave differently.
The proxy
An address that previously hosted other accounts carries history too, and a shared address links accounts to each other.
What to do about it
Do not equalise the load across the fleet — allocate it by condition: more to proven and aged accounts, less to fresh ones. An account that repeatedly hits limits should be kept on reduced allowances or retired, not pushed to match the rest. Costing attrition is in the ban-risk piece.