In theory yes, but in reality it has a plenty of distortion from various sources.

For instance the jitter - the early CDs didn't have a super stable clocks that governed the conversion, so the slight changes of the pace when D/A conversion takes place would create slight distortion and it would also affect intersample peaks making it more apparent. Then you have the non-linearity of D/A converters themselves that were essentially acting like waveshapers.