Some people are still missing the point here, DOS is not and never will be a programming language, it is an operating system. Very few people these days will be doing any DOS scripting, although they may be writing batch files to perform a series of command line tasks in the Windows environment (or whatever environment you choose that allows a series of command line tasks to be strung together into a batch).
A batch script written to run on whichever specific version/brand of DOS could be considered programming as it is a series of instructions that alter the state of a machine. C, C++, Pascal, ADA, Prolog, Fortran, BASIC, RPG, COCOL, Java, C#, ABAP are all examples of programming languages and it does not matter if they are interpreted or compiled, they are still bona fide programming languages.
MS-DOS is an operating system as is CP/M, Atari DOS/TOS, Dr-DOS, PC-DOS, OS/400 etc etc etc.