Before launch 3 AD was great in A, mediocre in B and started to suffer in C, just like most of the allied divisions. But now with the introduction of new units that can easily overcome and penetrate the former somewhat invincible jumbos (the king tiger wants to say hi), 3 AD is now just mediocre at best. It can not compete well on open fields anymore, its not made for infantry fights and the air tab is very limited. With a max AP value of 13 at 1200m (please do correct me on this if I got it wrong) its hard to overcome the heavy armored pushes on a open field in mid/late B and C, a problem that is shared among some other allied divsions. While other divisons can rely on their air tab or other units or they are simply not designed to be used this way, the only effective tool the 3 AD has at hand is the arty tab. If you manage to stun, panick and kill the stuff that can penetrate the jumbos, you have a chance. If not, well, good luck. What could be done abouit this, is either a buff to medium tanks in generell so that the 3AD is not so jumbo dependent anymore or a increase in the max amount of air cards you can take.
Edit: Another possibility could be a nerf to axis max AP value, so that the jumbos get their old bouncer-before-the-club-door role back.