The syntax for zpool upgrade shows:
upgrade
upgrade -v
upgrade [-V version] <-a | pool ...>
However, if you issue a 'zpool upgrade -V 999' you get the following:
bash-3.2$ zpool upgrade -V 999
This system is currently running ZFS pool version 8.
All pools are formatted using this version.
bash-3.2$
The return code is successful (0) even though this is not a valid command. This was found using zpool_upgrade_009_neg.