Happens quite often in every version.
https://www.youtube.com/watch?v=rQ43zqPS_z4

https://www.gog.com/forum/cyberpunk_2077/best_way_to_report_bugs_and_stuff

Its the "Z" element in the item's world location. I have noticed it happens on elevation changes, even if that change is because it's on something else.

There's also a fact that it's trigger is hidden behind something, even like the boundary of another item. I run a melee person and hitting around the object sometimes makes it retrievable. If it's a valuable/rare item, save game and reload. It can move it to the tops of the stack or a new location