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I think it's the other way round: Hata could afford to lift Athena up so much, way beyond what the other girls succeeded in, BECAUSE he always knew - in advance - that he'd take Athena out of the story afterwards, at least for the time being. And he added the "or I'll return to claim him" twist to throw a bone to the A-tan faction.
If she were to return, he'd either have to go for an ending soon, or he'd have to reduce Athena to the level of the other girls (which would certainly not please the A-tan fans). So I doubt that we'll see her anytime soon.
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