seems as the question is, if one considers the process of creating an artwork art itself. i guess people finding ingenious ways to create art with code can be considered some form of performance art. it still feels a bit far-fetched to me, but that's just a personal feeling, and as you've said, it's subjective anyways. interesting to think about.
i'd immediately agree for code which looks like art by looking at it, so in cases where the code really is the art. i can also imagine that there's code which looks like art and "generates" it as well, so that seems like code as an artwork.
for cases where code was written/engineered well to create an artwork with the least amount of lines, i'd consider the generated artwork to be art, and the code the result of a competitive coding challenge. again, subjective.
when comparing it to other forms of art i'm not that sure. i've mentioned performance art, which feels a bit like the exception breaking the rule. there's conceptual art as well. is the act of painting art itself? is a photographer finding the optimal place to stand to take a picture art? almost starts to sound like an artwork vs. artform discussion.