If Microsoft was playing hardball with Rockstar over the next version of GTA, as an example, Sony would be falling over themselves rushing to get it as a PlayStation exclusive. The console market and app market just aren't comparable.
Google basically says, "we have a store. Sell through us and we take a cut. Or sell directly, or through some other store, and we'll warn users that we haven't vetted that stuff for security etc."
I have no idea why you'd want to, but you can... UWP apps run just fine on Xbox and can be sold via the store - they just don't get access to the "exclusive" partition of the system (which you need to access certain system resources, such as > 2GB RAM). Sideloading prebuilt UWP apps is also possible. The exclusive partition is a different situation entirely - you need to be an approved developer to even access the SDKs.
I'd say there's a difference between what Xbox (and Playstation, and Nintendo) does compared to Apple by virtue of the consoles not being "open" development platforms (Xbox UWP aside). Anyone can grab the iOS SDK and start making apps, but only registered developers can do so on game consoles. Whether that's justified I don't know, I honestly haven't put enough thought into it. And whether courts would see that as a reason I definitely don't know.
Full disclosure, I work for Microsoft.
If anything, smartphone stores will be under more scrutiny.