The suggested role is to counter both M3 and Snipers.
Point here is that 223 cost 320/30 and has a pop of 4(?) which make it compare bad to Ostheer Opel.
There is not need for 221/223 to attempt feel some many roles. One should use different unit for these roles (221/223/Opel) and balance and design them better.
After re-reading a bit, I have to say I understand where you are comming from and why, but I feel like the 221/3 has a pretty defined role already in my eyes. Early aggression sprinkled with utility, for when AT weapons role out.
Im not sure how others see the commander, but I choose Elite-armor solely because of the scout car most of the time. Tank commander and heat just make it more playable because this commander basically only has 4 abilities. The sturmtiger is just not worth the headache.