TV OS's don't usually license high end audio codecs either or else you'd pay way more for that TV. Unless your TV is (very) new enough for E-ARC, the TV will only pass through normal DD5.1audio at best, even for apps like Netflix that support Atmos. If I connect the Apple TV direct to the old Panasonic TV then the audio must be stereo in and it will pass out stereo from it's optical: it won't accept surround signals in even I just want it routed out of the optical to a capable amp. It may be that the TV may not be able to pass-through DTS to a connected audio device (I'm assuming this would be optical out from the TV) if it has instructed Plex it only supports stereo, or other formats. I think the client app determines how the audio track is handled it uses the info gained from the connected playback device (TV or AVR).
Not had any problem playing any of the different audio tracks from these MKV files regardless if the amp is two channel or surround. Out of interest I dumped them in a separate Plex library and streamed to Plex app on my Apple TVs: ATV HD is optically connected to a stereo amp (extracted from HDMI switch), and ATV 4K is HDMI to Denon AVR. These tracks have 2 and 5.1 channels versions of each type.
They have a variety of audio tracks: TrueHD, DTS-HD MA, as well as normal DD and DTS, and LPCM.
I've a few Blu-ray converted direct to MKV.
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