that would mean that the server never received the file.
most likely due to a server setting for post max time or max file size, or another one of the settings that effect uploaded file size.
In order to be able to report that the file does not meet the size restrictions that you set, the server must be able to receive to receive the file, only once the temp file is sent to the server can the server know it's size and reject it or save it based on your settings.
if the server cant accept the uploaded file due to server level restrictions, there is know way for the php processor to implement the restrictions you are setting.