It might be an accurate statement, but the unit is meant to do so many things.
That's how utility units work.
They do other things that are not combat that inflates their value/takes away their combat capability.
221/3 was never meant to be pure combat vehicle.
It was always meant as a form of fuel cache that isn't opel blitz clone.
You are looking at medkits, detection, mines and resource boost as extrase.
Its the other way around, the gun is extra on this unit.
Glad to see that you that you agree with my point.
And the problem with current implementation is that:
1) One can build the 221 a soon as it available and delay access to crucial tools like faust/ST44 upgrade/Luch for a unit that UP as combat unit, in the hope that in late game if his 221 survives and he chooses to invest more to upgrade to 223 he can eventually get some economical return back.
2) One can build it after setting up his truck when the timing 221 is late can easily be countered.
3) One can use the 221 in the front line where it rather weak and utility is not very helpful (medic kit do not heal in combat unit can not reinforce)
4) One set up the 223 and not really benefit from the so much advertised "utility". Recon only too far back, mine at vet 5 which is joke, healing not really helpful in back line.
In sort the design of the unit is not optimal and it can easily be improved, there easy change that can make these do less but do them better so that people have more reason to use them.