I'd say that there's no reason if your base hosting plan provides enough space/bandwidth. Where I think it's useful is when your file transfers become enough that you have to look at buying an add-on of storage/bandwidth from the provider -- in that case, S3 may be a viable alternative. But if I'm paying $X/month and not using all of the storage, there's no upside to it.
On the other hand, if your capacity planning calls for you to someday exceed the provider's limits, S3 may be a good solution from the start so you don't have files being served from multiple places.
