They are, in the sense that Penals are not a good squad template to be lugging around AT rifles.Their reinforce is too high at 27 and mobilize reserves doesn't help them at all in this regard.It would make more sense to give the soviet CE 2xPTRS instead or Cons PTRS non-doctrinal.
1/ because PTRS penal is light AT unit, it costly but effective vs LV and ground control (protect Su-76, T-70, Quad grinder from being chasing). By forcing Penal go PTRS, you had a upper hand on INF fight later on. Is that enough for balance ?
2/ Giving PTRS to CE is pointless since: they are too weak for anti tank job. With Hurra + snare + PTRS, Con could 1v1 everysingle LV in game, even give a bigger threat to medium tank. Not to mention is overlap with Tank Hunter doctrine.
3/ IF you want a AT inf solution without draw back, I am sorry but not in this game.
Back to this thread, OT fault is not keeping a good distance from eniemes troop even he knows Penal could go for PTRS as emergency solution against LV. Second, instead of running out he should charge into Pental and "eye for an eye". You see, this is L2P issue rather than balance or "bad design"