There were a number of occasions during WW2 where US subs torpedoed enemy boats on the surface, (USS Batfish sank three surfaced Japanese subs on one patrol in the space of a few days) and one US sub, the Corvina, was torpedoed on the surface by a Japanese sub. The problem under the water was getting accurate firing data from just the hydrophone. You might be able to get a reasonable bearing and speed estimate, but what about target depth? Very tricky stuff with unguided torpedoes, so subs underwater generally avoided each other.
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