Comodo is capable of extraordinarily complex rules. This is way too much for typical user so Comodo developers optimize CIS for the least amount of alerts so as not to overwhelm users.
To make matters worse, the CIS user-interface is all manner of confusing quirky behaviors (bugs). Add to all of this a problematic combined Cloud service - and it just ain't good for the average user.
I will state this much: I will gladly put my customized CIS configuration up against any AV test lab.
That's the point - CIS needs experienced user who is willing to craft his\her own rules and policies. That's something even "advanced" users won't even dare to mess with. Do it incorrectly and you have smashed, unbootable system.
CIS is not for amateur night - and at the same time - the AV-Test is not designed to comprehensively test Comodo nor any other AV for that matter. There are those that know precisely what I am talking about - because they understand what AV-Test evaluates and does not evaluate.
So those are some of the facts - and just won't change until Comodo refines their product = fixing bugs, eliminating questionable features, making CIS management\administration more user-friendly, etc.
I am experienced CIS user - and, in my experience, CIS is just plain overkill for typical use. For it to be effective it requires too much manual administration and how it works is incomprehensible for average user. I use it because I genuinely like it; it is configured to behave (for the most part), is quiet on my relatively simplistic system, and it handles malicious files like no other AV that I can find. So for me, it personally works. That is not true for the vast majority of users - which is Nico@FMA's argument. And, unfortunately, that is Comdo reality...
Anyhow...
I tell it like it is - Comodo is very good in some respects, but at the same time, has a lot of issues that sow nothing but confusion with most users - and it is not intended to be a complete internet security suite. CIS is designed only to keep the physical system clean - and not stop malware from getting onto your system (which is the whole premise of AV-Test methodology).
Comodo is "Old School" and its management can be way too laborious for the uninitiated. My CIS config keeps my system clean despite heavy malware testing. The defining factor is I know how to use it to its fullest capabilities... so, despite what Comodo says, CIS is best suited to techies and security soft geeks. That's it.
Bottom line: If you can do it, then CIS can do it...
Good - yes, Great - no, needs refined, Garbage - absolutely not