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For example CS4328, which Miska mentioned, is not a "DSD DAC" because the term "DSD" did not exist at that time, so it is more correct to call it "1-bit delta sigma" as you mentioned. Also notice it was advertised as an 18-bit/48kHz DAC. In this sense there is also no need to secure more bandwidth beyond 24kHz and it can use a more aggressive analog filter to remove ultrasonic noise. Also notice the word "18-bit". For DSD64, it is entirely possible to have more than 24-bit of dynamic range below 20kHz in
digital domain, but the price is to use a modulator with more aggressive noise shaping, which means the rise of > 20kHz noise will be more severe. Those Crystal designers probably found that 18-bit/48kHz with an appropriate analog filter was the best combination -- a modulator with good enough dynamic range and bandwidth and low enough ultrasonic noise which can be effectively filtered by the analog post filter.
The reason that I emphasized digital domain because for a modulated digital domain DSD signal (aka DSD file), the noise can only be moved, but not removed. The noise can only be removed by converting it to multibit with a digital low pass filter, and/or of course, in analog domain. If the filter is too weak, the ultrasonic noise in analog domain will fold back to the passband due to intermodulation distortion, the result is rise of noise below 20kHz. So ADC aliasing is not the the main or only reason of the rise of noise below 20kHz.