What are they counting as Europe?
Going purely by the 'Others' category on this site (and assuming Europe is a big part of that) then it's possible as:
360 launched around November 2005 in Europe (correct) as has sold 5.44 M in 'Others' in approx 25 months and with 3 holidays under its belt.
PS3 launched around March 2007 (correct?) and has sold 3.90 M in 'Others' in approx 10 months with 1 holiday under its belt.
So yes, looking at those figures its in with a shout - but a lot could affect that both ways - i.e. how GTA and MGS go on PS3 vs GTA and other exclusives on 360.
Try to be reasonable... its easier than you think...