The reason for this behavior is that when you do not set limits on the size of the form, Delphi will automatically receive system-level restrictions through a message WM_GETMINMAXINFOthat starts when delphi sets the size of the form using a function SetWindowPos. For maximum height, Delphi uses the ptMaxTrackSize.Y element, which on my Windows 8.1 system is 1092 (resolution 1920x1080).
Therefore, if you want the height of the form to be higher than the height of the desktop of the system, you must use Constraints.MaxHeightto override this behavior. You can verify this by setting a breakpoint in the procedure TCustomForm.WMGetMinMaxInfoin the block Vcl.Forms.
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