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If the signal chain and/or audio format involve floating point, the maximum level can exceed 0dBFS. That's why people should use the internal software volume control and/or ReplayGain to avoid clipping.
Please read every link in the post below.
https://www.audiosciencereview.com/...lity-in-windows-using-wasapi.5272/post-116878
I think it's a bit more complicated then this, see Intersample Peaks and the possibility of overloading the DAC. Some DAC's eg Benchmark DAC3 & RME ADI-2 FS are able to handle Intersample Peaks between +2-3dB.
Archimago has a lengthy discussion here - - > http://archimago.blogspot.com/2018/09/musings-measurements-look-at-dacs.html
Edit: @bennetng beat me to it ... ;-)
Ok, I think we actually all agree, I was just not precise enough in my language.
When I said the maximum level would never exceed 0dBfs, I didn't intend to suggest that intersample clipping could never occur when the level is set at 0dBfs (that depends on whether the DAC is designed to handle this properly).
What I was intending to get across was that using digital volume control will not exacerbate (and in fact will tend to prevent) intersample clipping.