While it's true of some languages, it's certainly not true of all of them. I'm not sure most is accurate either. JSON is a subset of JavaScript, so it stands to reason that JavaScript could have as many indentation levels as JSON without a loss of clarity. It also stands to reason that any language with hashes, dictionaries, etc could feasibly exceed 3 indentation levels without it being a red flag, particularly if those hashes are in a method that is already indented more than one or two levels.
Well, Torvalds said that about C where you have no indent at the class/namespace level. So I'd argue it can be a bit more for languages that have this (most of the popular ones), 4-5 I guess.
So for those three levels, do I have to count the object and method-level indents, or is it a rule for languages with unindented includes?