I'd say so. It's a transport that can transport things that you shouldn't be able to transport... and it's got 3 structure points. I fought 8000 points of Orks this last Friday, and there were Kans inside the Skullhamma... my Assault Marines got the jump on it since it was deployed near No Man's Land and a table edge, and I had the first turn... I blew it sky-high with a power fist and meltabombs from the squad, but then the Kans came out... I didn't realize it was a transport until then. Quite a nasty surprise, really.