SDK Manager and Headless Mode

Is it possible to use the SDK Manager to update a headless TX1 to a L4T version greater than version 32.1 using a re-enabled oem-config to create an initial user and password?

The key is to ensure there are no USB mouse/keyboard or HDMI monitors connected to start headless mode installation. Once the OS is flashed, use the USB serial console to complete the Ubuntu installation and create a user/password. Use IP address 192.168.55.1 as the device IP to get SSH access to new target OS.