The entire 5150 BIOS fit in 8k, so even if it were laden with BIOS calls (which it's not) then that would be an upper-bound.
And it depends on DOS configuring the memory space to leave an INT 20h call (to terminate the program) at a place that's easy to RET to.
This has always been the case, and actually inherited from CP/M.
Sure, it saves a lot of bytes compared to PCM encoded wave-form data, but it's not really cheating anything unless we also consider the red, blue and green parts of the computer monitor to be cheating because we're not outputting colours as raw wavelengths, but instead the monitor is decoding compressed signals into actual colours.
Of course: https://www.pouet.net/prodlist.php?platform%5B%5D=Atari+VCS&...
and yes, your observations are spot on.
I expect someone will then say "though in practice today it's 256 bytes of binary plus a whopping 64kB of BIOS ROM and 16kB of video RAM" ;-)