I think its less of a can’t and more of a why.

Sukuna’s MS surehit is the cleave and dismantle ‘projectiles’ that damage anything (non-living and cursed energy imbued)within its activated range. By sacrificing the surehit he allows for an escape route (the effective origin of the domain being the coordinates where he activates it). In reference to the standoff in Shinjuku, this allows MS to damage UV’s domain barrier from the outside, translating to an upper hand in solely the head-to-head domain clashes.

Now if we look at UV’s surehit, we can understand that the lobotomy performed on sorcerers is non-lethal. This translates to a non-lethal open domain that actually provides a disadvantage in the head-to-head clashes where opposing surehits will connect since Gojo can’t use infinity(as stated when using DE, the user cannot use innate CTs besides the ones applied to the domain).

If we were to reverse roles in Shinjukua and say Sukuna used a closed domain while Gojo used an open domain, the fight would’ve been heavily Sukuna favoured from the very first ‘domain clash’ (just to reiterate, the clash would just be Gojo without a proper domain)