This is a question for App Review to decide upon. One observation - if the current version of the app is for the iPhone, there is an App Review requirement that all iPhone apps run on the iPad (in iPhone mode). In fact most reviews are performed on an iPad and for this reason, the issue with failing to operate properly on an iPad is detected. So in the upgrade which you propose - features that were available in the earleir version now require in app purchase, but the iPad version runs in a native manner on the iPad.
Unless the App Reviewer is knowledgeable with the app, they are likely not to be aware that a previously "free" function is now an in app purchase item. I have no idea as to if an specific App Review guideline might apply. However, I think the issue will be discovered by your existing users, specifically those who may be using the current iPhone version on an iPad and are expecting the "free" feature to just work. On the other hand, the iPad app is native.
rich kubota - rkubota@apple.com
developer technical support CoreOS/Hardware/MFI