One of the quick tests I like to do to ascertain the complexity of a codebase is "how long does it take to find the entrypoint" and "how long does it take to find the core functionality"?
In this case, I have been clicking around through nearly empty directories for 15+ minutes and haven't seen anything that looks like an entrypoint yet, nevermind the main loop.
In contrast, I downloaded the Bash source and within 5 minutes found the main loop (eval.c) and entrypoint (shell.c).
Now I'm curious to know what the cmd.exe source is like, but MS seems to have no intention of releasing that.