Just by the fact that it has APHE. Again, compare my stats in the NA 75 and the Ch 7. I played both in the same 4.7 lineup.
Again, how?
Marders, SU-57s, ZiS-30, LVTA with the 57mm, swedish HEAT slingers.
If we go up a bit, then M4A3 105 with HE just overpressure, and pens it with HEAT, StuH overpressures and pens it with HEAT, soviet 76mm LOLpens the turret roof, SU-122 overpressure and pen.
If we go a bit up, to ~4.0 and over, there are basically every Panzer 4, StuGs, M10s (and every tank with US 76mm), SU-85s, Dicker Max, Emil, Flakbus, Hetzer, Jgpz 4, Protopanther, JaG-10, KV-85, Chi-To/Ri, Na-To, Italian Bredas, and Fireflies, M4A4 SA50, Pvkv TDs, Delete Tom.
And these are just those that come into my mind.
And the rest can still pen the cupola.
The Chinese M4A1 is much stronger in a hulldown (and in general), because of several factors:
Can reverse faster than the speed at which a continent moves
Has APHE, so 1 shot is enough most of the times
Has a stabilizer, effectively guaranteeing the first shot
Has a .50 cal, so many times you don’T even have to expose yourself.
Smaller target in hulldown.
Angled front makes it effective, while the Comet is just a box, that you can’t angle.
Much faster reload.
Ammo stored in the floor, instead of everywhere.
Nearly double the turret rotation speed.
Can turn on an incline.
Just like the Chinese M4A1. As i said it is even stronger in hulldown.
Or a T-34 1942/43 if you hide the neck. There are 4 small corners that you can pen, but for the rest you need ~130mm pen to go through the double layers.