I tested it in random battles.
I post here a couple of results, both are lost games and if the combo of tank and player was not able to carry the team to the victory i would say that the problem was on the player side, i am far from being a pvp specialist or an unicum player. The game of the second screenshot was lost for time, it was assault mode on Pipelines, and I was very low health so i could not push to kill the 2 remaining enemies, that was at low health also and whose positions was known.
I would say that this tank destroyer can perform well also in random battle, even if it lacks of burst damage not having a rack. And penetration, even with ap too many mbts at the same tier are really hard if not impossible to penetrate frontally at the typical distance a TD shot.