I really don't think it would make a difference either way. Owner's manual for my '94 ZJ states:
TC - Mopar Automatic Transmission Fluid or equivalent labeled Mercron or Dexron II.
Tranny - Mopar ATF Plus (Type 7176) is preferred.
Notice, the tranny says ATF Plus, while the TC says ATF. I really don't think it matters, though. It's only 1.5 quarts, so you're not looking at a big price difference if you want to use ATF+3. Personally, I'll just stick to what the owner's manual says.
'94 JGC Laredo (ZJ), 4x4, 4.0L, 42RE, Select-Trac