I have never seen TODOs being cleaned up in enterprise environment. Therefore our team would not approve PR with TODOs: either fix them yourself or open a separate ticket for it.
There's no back-link mechanism for a ticket. If there were (when viewing the code there's some visual queue that there's a todo ticket open for this line) then I'd agree. Also consider the infuriating practice where managers (often with the help of supercilious bots) close tickets "just because".
