I can see merits in using non-oversampled DAC's. Just output exactly what the DAC gets, without interjecting anything in between samples. Any ultra-HF artifacts are filtered by the upper rolloff of the system. That's the filtering mechanism of a setup like this - It's simple and attractive for those going for a minimalist solution, which is important to many of those that like SET's, reduced component counts, small signal path, etc. So I think there are advantages that can be exploited in both oversampled and non-oversampled approaches.

Wayne