7.2.3 says out of command unit can't do any action during its formation impulse. It also says an out of command unit can execute Opportunity Fire during enemy impulse. 7.2.3 does not say the out of command unit can do anything else. It's basically silent as to any other action.
13.0 specifically clarifies that defending units marked ops complete may counterattack. I say clarify (or exception) as normally ops complete units can't do anything further when so marked. It also specifically clarifies that disrupted units may counterattack as well, but with a To-Hit number of 6. This is again, a clarification (or exception) because disrupted units can pretty much only move, with restrictions, during their impulse.
13.2 says the defender, if eligible, may counterattack, but it doesn't really define eligible. 13.0 seems to suggest though that eligible means a defender who has an appropriate FP that can affect the attacker. Out of command units could fit the bill, but so could ops complete or disrupted units, yet a clarification was made for ops complete and disrupted units, but none for out of command, and we still have 7.2.3.
1.5 says if the rules do not state that your units CAN do something, they may NOT do it.
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