A single GV troop carrier should not be able to capture alone.
Sneaking in an M3 happens often due to the very low icon ranges and small dot. a C47 is almost impossible to sneak in - its silhouette is big and distinctive, icon ranges are longer than for GVs. A C-47 is an easy kill to any fighter, while an M3 is not so easy to kill with guns, especially for planes without cannons. In practice, to get the C47 in, a complete momentary air superiority is required, while M3 often brings the troops through the action. How many base capture with goons have you seen lately? From my limited sampling, M3 captures are much more common.