If you move up in the rankings you will almost be guaranteed a higher CTR. So, moving up will bring you a return.
But will that return make a profit?
I believe that it is important to consider who is above you. If you are a tiny local business at #4 with 22 backlinks and the three positions above you are Goliath Brands at #1 and #2 with 1,000,000 backlinks and Major Publisher at #3 with 900,000 backlinks then you might be attacking the US Navy with a slingshot.
In those situations, all is not lost... you still have your title tag that can be used as a lethal weapon. What is your value proposition?....
-- offer a kickass price in the title tag
-- offer immediate free shipping in the title
-- tell them you have the "Secrets to Success"
-- tell them you have "Free Beer"
These will get potential customers onto your website.
If you have something to brag about you should be using the kickass title tag all of the time... but it is especially important if you want to elicit clicks away from the site that ranks above you and that you have little hope of beating.