Through-hole manufacture adds to board cost by requiring many holes to be drilled accurately, and limits the available routing area for signal traces on layers immediately below the top layer on multi-layer boards since the holes must pass through all layers to the opposite side. Once surface-mounting came into use, small-sized SMD components were used where possible, with through-hole mounting only of components unsuitably large for surface-mounting due to power requirements or mechanical limitations, or subject to mechanical stress which might damage the PCB.
A component might not be able to be made any smaller because of its mechanical limitations or what other need? (If the question is unanswerable, say "unanswerable")
power requirements