You have to pick an audio stream that can be direct played by the Plex client. Check the technical specification for your TV set and choose audio tracks which are supported by your TV.
Plex defaults to the first audio track in the container (*). So, for example, if your movie has both TrueHD and AC3 audio, remux the file so the AC3 audio is the first audio track.
Blu-ray movies with dts-HD audio must also include a standard dts audio track. Blu-ray movies with TrueHD audio must also include a standard AC3 audio track. So, in theory, you should have access to an audio track your TV can play (if your TV supports both AC3 & dts).
If you do not have access to an audio stream your TV can direct play, you can use a combination of tools such as XMedia Recode (transcode/remux), Handbrake (transcode), MKVToolNix (remux, MKV only), and Subler (remux, MP4 only, Mac only) to transcode/remux available audio as needed.
Note: Watch out for subtitles. Some (all?) Plex Smart TV clients do not support image based subtitles such as PGS & VOBSUB. Enabling those subtitles forces a transcode. Also, be aware that enabling SRT subtitles while audio is transcoding will also force a video transcode. SubTitle Edit is a good tool for translating PGS/VOBSUB to SRT. The OCR process can be laborious, but it is the best tool I’ve found to accomplish the translation.
Example:
I have a LG B7 OLED. It direct plays AAC/AC3/dts/dts-HD audio streams up to 5.1 channels. Any 7.1 audio stream is transcoded, as is any TrueHD audio stream, since the TV does not support those audio formats.
So, when watching a movie using the LG Plex client, I specifically choose a supported audio stream. I avoid dts-HD MA 7.1 & TrueHD audio streams as they always transcode.
The Plex LG client is also susceptible to the previously mentioned subtitle condition. Therefore, I do not enable PGS/VOBSUB subtitles, or SRT when audio is transcoding, to avoid video transcodes.
(*) Your PMS language settings may have some effect on which audio track is selected first. I’m not sure what would happen if, for example, PMS was set to prefer English and a non-English audio track was present before an English audio track in the movie.