Hmm, it's weird. Now I got back from the school and experimented with it:
After studying, I extracted the boot contents from the CD image which has 1.44MB fdd emulation. Signature "WinISO" is on the emulation. These files were BOOTLOAD.BIN and CLASSIOS.KXE (which loads SHELL.EXE) and WinImage provided a boot floppy which contained these files, since they aren't visible normally. So I ran Bochs with this "FDD emulation floppy image" which contained just these two files and it asked for SHELL.EXE, so I added it and removed the DLLs on purpose. Kernel fault and it looped infinitely, there was a 32bit register dump . How many DOS'es did you saw lately that created a kernel fault and displayed 32bit registers?
Then I included the DLLs to the "emulation floppy image" and it ran successfully, believe it or not.
I thought they were DOS applications, but they seem to have "This program cannot be run under Win32" message, which outputs the 32-bit delphi compiler (C for Win32 displays "This program cannot be run under DOS mode." under DOS). So I tried to execute both SHELL.EXE and HELLO.EXE under pure DOS and it displayed that message.
Executing the standard SHELL.EXE under Windows environment works normal btw. So I made a test Win32 console application in Delphi that would just display a message, and renamed it to SHELL.EXE. No custom System.dcu, everything standard. I've ran the floppy again with my application and it did a kernel fault and looped.
Conclusion? You decide. I've attached a archive, that contains two floppy images of the "ClassiOS" loader from the CD image. The first - clasios_1 - has the standard shell, the second image has my own test application. Run it, delete the DLLs, or do what you wish and see for yourself.
It doesn't seem to be MS-DOS kernel though - again, SHELL.EXE doesnt work in DOS.
The archive can be downloaded here:
http://inflater.wz.cz/osdev/classios.zipWeird, very weird.