It appears that the names given to code sections and those used as regular code labels are created in the same namespace by gpasm. Thus the following example fails due to the use of "test" as both a code section name and code label.
test nop ; do something here
F:>gpasm -c -p16f887 broken.asm
broken.asm:5:Error  Duplicate label or redefining symbol that cannot be redefined. (test)
Under mpasm the above is legal and appears to have no ill-effects, suggesting that these namespaces are regarded as separate. So, this is a compatibility issue for pre-existing code.
(gputils 0.13.6 and 0.13.7 on Win XP, mpasm 5.11)