What you just described is done in every game. It's called frustum culling. I suspect that you are not accurately depicting the "cheat" you're referring to. Otherwise, what you just said isn't cheating.
No, it was cheating and it was by nVidia. It's the reason why decent reviewers haven't relied on 3DMark ever since.
http://hardocp.com/article.html?art=NTQ5
http://www.techspot.com/news/5468-nvidia-caught-cheating.html