If not, then fingerprinting could still be done to some extent at the IP layer. If the TTL value in the IP layer is below 64, it is obvious this is either not running on modern Windows or is running on a modern Windows machine that has had its default TTL changed, since by default the TTL of packets on modern Windows starts at 128 while most other platforms start it at 64. Since the other platforms do not have issues communicating over the internet, so IP packets from modern Windows will always be seen by the remote end with TTLs at or above 64 (likely just above).
That said, it would be difficult to fingerprint at the IP layer, although it is not impossible.