Correct, it's $529: http://store.apple.com/us/buy/home/shop_ipad/family/ipad/ipa...
That's the iPad 2. If it's comparable to the Surface, then your point is valid.
The cheapest iPad 3 with 3G costs $629.
And while YMMV, I don't require 3G on my tablet. I already have 3G on my phone, which is always in my pocket, and I can create a personal hotspot if reqd.
The new iPad has a Retina display but beyond that ? (I'm talking about hardware)
You can't even buy an iPad 2 with more than 16GB anymore.