That is correct. It is cheating, but the judges let a small amount of it slide, especially if you come up with an amusing enough justification. I could not get it to fit otherwise!
I'm not a judge or a competitor, but I feel like a little bit of cheating on the rules is within the spirit of the game. Especially if it a) it makes it more obfuscated and b) it wouldn't have fit otherwise.
Considering that one historical entry (winner maybe?) consisted of a source file that simply contained the character ‘c’, plus a makefile, I’d say it’s in the ball park.