To clarify, the rules as they are means yes it's opposed Stealth vs Perception, my preference in how the rules should have been is that the DM takes the situation and comes up with a DC same as other skill checks. Look at the situation and make a call on how easy/hard the task is which gives you a DC. Tailing someone through a crowd might be Easy so DC 10, moving silently over creaky floorboards might be Medium so DC 15, moving from one area of cover to another during a guards momentary distraction might be Hard so DC 20, etc...