Dear DARahman
Wa alaikum assalam
Please see my responses to your questions in red italics.
1. Do you agree that Allah does not describe the Qur’an as “Holy”
Yes, as far as I know, the Quran is not described as 'Holy' (Quddus) in one sentence in the Quran.
2. If Allah has not described the Qur’an as “Holy” can it be said translators and commentators of the Qur’an are overstepping by using language to the describe the Qur’an that Allah has not used?
No as there is a strong / plausible reasoning which could explain the translators cogent inference. If the Quran is revealed by God and God Himself is described as 'Holy' (Quddus) in both verses 59:23 and 62:1 of the Quran, then what does that make the Quran if not Holy (as well as other descriptions)?
Therefore, I personally see nothing wrong with the Quran as being referred to as Holy.
I hope that helps, God willing.
Joseph