Yes, occasionally this does happen to me too.

From: Tom Rash 
Sent: Tuesday, January 12, 2016 8:59 AM
To: viphone@googlegroups.com 
Subject: Apple TV 4 remote

Is anyone having this problem?  When I turn my TV off with the Apple TV remote, 
a lot of times after a minute or so, the TV will come back on by itself.  
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