True on the Wrangler TJ. It can help on some cars though, some air intakes have purposely added restrictions for reasons that include making it quieter to (surprisingly) reducing power. The Corvette brass at GM forced the Camaro people to reduce the power of the Z-28 because it was found to be faster than the standard Corvette... they did do by restricting its air intake. The Mustang 5.0L also has a restrictive air intake. Replacing their intakes with a performance/non-restrictive air intake can really boost their power.
The TJ, however, does not have a restrictive air intake so its performance won't be enhanced by swapping on an aftermarket air intake.