If the area of the hole approaches that of the container's cross-section, the entire fluid just "falls" out of the container;container in bulk; there is no jet efflux. So, in such a case it is not meaningful to apply Torricelli's theorem.
Torricelli's theorem is based on Bernoulli's Principle, which assumes steady flow. In such a case, the flow is not steady. So, the theorem cannot be applied.