For combat: 221 will lose to Universal Carrier and M3. 221’s mg lacks penetration. I have tested in cheat mode.
For utility: 221 can drop medic, but can’t carry infantry. Universal Carrier and M3 can carry infantry. It is useful for vehicles which can’t capture. I think 221 has same utility as other early vehicles.
For cost: Here is the problem. 221 is much more expensive than other early vehicles.
My suggestions for balance adjustment:
1. Reduce 221’s fuel cost by 10, but increase 223 upgrade’s fuel cost by 10.
2. Incease its mg’s penetration, so it will perform better against other early vehicles.