It's even true for reconstruction. A digital waveform can represent peak levels far above "digital peak", in between samples.
This is why if you're mastering songs, you'd better keep your peak levels at -0.5dB or -1dB so (so the filtering from lossy compression won't make it clip), and why you'd better use an oversampling limiter. Especially if you're doing loudness war style brutal limiting, because that's the stuff that really creates inter sample peaks. But you shouldn't be doing that, because Spotify and YouTube will just turn your song down to -14 LUFS anyway and all you'll have accomplished is making it sound shitty :-)
