Comet is not inaccurate, it simply (probably) can not hit via collision...
And that's why it becomes too inaccurate. Let's say both tanks shoot at a vehicle with a target size of 20 (a StuG for example) at far distance. Both have a 60% chance to hit it. However, if they don't hit, there´s a good chance for the Panther to hit with scatter. The Comet does not have that chance.
The overall amount of hits matters and is perceived as accuracy by the player. I did not argue about the accuracy modifier.