I can confirm this.
Had several fights with my BBs vs CA/CL/DD with small caliber guns which didnt have a chance against the belt armor (12"/18"/12") or even the super structure(8").
All damage taken, as shown in the logs, was from deck hits @ Range ~5k and closer most of the time.
My only explanation would be richochets from the super structure.๐
PS: Also happens with my own shells apparantly. CA @ 4-6km range, BB @ ~8km:
PPS: The number of partial pens with very low damage seems a bit high (e.g. 160DMG @ 65 hits taken). DMG notes with 0.x partial pen is also rather common for me and I suspect this is from the hostile ships spamming HE on me.