I think its all about use of material and possibly the cost of heading the fastener.
Hex head bolt is a large amount of material to be displaced to get the head. Internal wrenching fasteners use less material and less amount displaced to make the head.
But, if you cut apart a standard socket head (internal hexagon) bolt its pretty weak down at the bottom. The torx with its higher torque transmission capability, allows a smaller internal recess and so more "meat" in the bottom of the fastener and again the smaller amount of material is working more uniformly as a stressed piece.
Auto industry is famous for trying to shave cents because of the 6 to 8 figure volumes, especially in fasteners which may commonize across many vehicle platforms.