222 should have the exact same gun stats as the Luchs with armour comparable to the M20 imo (so 11 from 9). No health increase. Dunno what cost should be (thinking 40F), but that's how I think it should perform.
Main thing is it can't be made to outperform the US AAHT, because otherwise you kill the Lieutenant tier.
And now tell us how do you counter M20/M3/Bren if you 222 hit the field 3-4 minutes later than today? And for which benefice? better IA when 1-2 minutes later comes Stuard/T70 that 2-shots you?
I'm sorry to tell you that but this idea to increase 222 price is stupid.
222 counter light vehicles play but not light tanks and not infrantry.
You want to counter light tanks, combine your units, you have shreck,pak,222,faust until you build a stug/Pz4
You want to counter infantry, you have MGs and Sniper.