Some folks think outside the box and do their own testing.
Ballistic gelatin is more of a "best case ever" situation for a bullet... add in some bones, odd angles, stuff encountered before the bullet can get to the gelatin and things start going differently.
Some folks also think about much more evolved enemies foreign & domestic that don't just stand still wearing a light shirt out in the open.
Once hard barriers get involved, you'll see the difference very quickly.
I knew you'd harp on the BG refernence.
Its designed to simualte penetration in humans, cuz shooting actual humans to do this kind of testing if frowned upon.
And its often tested with a clothing like material in front, due to the fact ppl seldom walk around nekkid...
and also to test for clogging of the hollow point that turns it basiaclly into ball ammo.
9mm over penatration is a real world consideration ... even when shooting things with bones. I am drawng on real world "testing" ... actual real world shootings... police, personal self defense, homicides, etc. 40 S&W has even greater risk of over penetration...in the real world
The likelihood of me encountering ppl wearing body armor is minimal. Irrelevant, really. To me, anyway.
On the whole, 9mm 147 grain does 95% of what I'll ever need it to do...while minimuzing risks of overpenetration.
I come at this from the perspective of someone who was SLED certified in South Carolina to teach concealed carry (have since relocated) , and its related concerns and practices.
If yer in combat / facing ppl with body armor ....feel free to disregard. That's an entirely differnt discussion.