That information about stuart killing/greater AOE is very informative. Though I feel like if you were going to kill a stuart you'd of done so because it was low and you were chasing. I can see instances where a stuart is caught out against a P4 and you want to kill it fast and thats when the HEAT shells would be good. I'd be ok with the ability not being universally useful if the other commander traits made up for it.
My issue is if you don't get a 221, then why bother going that commander? It's a deadslot and I always think commanders feel worse if something isn't an option, but a BAD option.
If a tank has a sight range of 35, and it gives 45 range that's still not that much. I think around 50+ is the sight range that turns out really good. Otherwise you can barely see an MG but not much else and if you want sight you're better off with units that have stealth/scout way better since you aren't putting the tank in danger.
Also I dare someone to try calling that tank commander arty on AT guns. Not only do you have to be somewhat pointblank, but it takes longer then normal artillery to land, takes a good 8 seconds. It's a weird argument that a basic LMG upgrade competes with what should be a highlight feature of a commander.
The Sturmtiger I think becomes an interesting unit at vet 1. The grenade launchers cause a constant threat and force enemy targets to move and I think that's where the ST shines. Forcing your opponent to constantly reposition in and out of cover. The issue is that the sturmtiger shot is inconsistent and just doesn't wipe or hit properly. Wheras the Avre is consistent and hits the target everytime and wipes.
I'm generally convinced that not all commander slots always need to be useful for a specific build but can instead also be valuable by simply providing options (think of Airborne's MG and AT-gun drop, for instance, or the Opel Blitz in Firestorm). However, that doesn't really apply for the 221 as it more or less pigeonholes you into going Battlegroup due to the steep fuel cost, especially for the 223 upgrade. So while the unit itself is pretty good IMHO i can understand the frustration that it effectively locks out teching options rather than to create ones.
Concerning the Panzer Commander, the +10 sight range may not turn the Tank into a recon vehicle but it effectively allows you to use it without spotting support, such as when flanking or hunting down wounded tanks or rocket arty. The greater vision also means you're much more likely to get the first shot off against enemy armor, which can make the difference between winning and losing a fight. It also helps against running into snare-range by accident when attack-moving through the map, as well as letting you see a potential AT-gun ambush from decently farther away.
Also the off-map may be rather crappy and take ages to come down, but it's not so much about actually killing AT guns with it than forcing them to move OR get killed. For a mere click you'll force that little bit of extra micro tax on your opponent that might be lacking elsewhere in return, plus moving the AT gun(s) will often take them out of the fight for long enough to overwhelm them or get out of their firing arc.
Is all that worth passing on the pintle MG? Maybe not always but in many cases I'd argue it is. After all the Panzer Commander upgrade wasn't removed from the OKW Tiger for no good reason a couple of patches ago.
As far as the Sturmtiger goes, I agree that the Vet 1 grenade launcher is pretty decent. I also feel the changes to projectile speed/arc further made it quite a lot more reliable, at least as far as I can tell from my limited testing. Not sure if that'll be enough to make the ST more competitive, but it sure is a step into the right direction.