If the list was being prepared to compete in singles tournaments, then I would say: unless you get a lucky paring you cannot win too many games. But hey, this army is meant to go to ETC in the end and in the ETC environment, the pairing procedure can help you avoid at least some difficult matchups.
So now that I know what is the perfect counter to KV 85 based Tankovy, I also more or less understand what is this army fit enough to beat. Following up on this, I am now able to upgrade my list to version 2 :)
To start with the pros, I think that the way it is constructed, Soviet Tankovy can beat a lot of infantry companies (minus AT11+ spam) and other tank companies that were built to crush infantry. It has a lot of options to get anti-infantry focused units and also some possibilities to reinforce it's anti-tank capabilities.
For anti-infantry, I can get one of the best Mid War assault tank units: Matildas II CS. It is funny, that 10 of them only cost 430 points (after the 'downgrade' to CS) because with armor of 7/6/2 and a 3+ firepower, rof 2 gun they are the bane of <AT 10 guns as well as non-pioneer infantry units. Of course, the obvious disadvantage of these tanks is that without a tank escort to help during close combat, you will not be inflicting too many hits with average rolls. Other than that and the 'slow tank' rating, they are your perfect infantry mincing machine.
As a secondary assault unit that is also helpful in wearing down anti-tank defences before real action begins, I would pick T-60s. For what they do I think they are pretty damn cheap. With 10 tanks only costing 180 points, with a decent front armor of 3, a machine gun and a 20mm AT5 gun, they are the perfect throwaway unit I can use to kill a couple of those Pak40 guns before my unit explodes (and hopefully I can keep one out of enemy LoS so that I avoid yielding small points).
Now that I have my main and backup anti-infantry force, I need to think about how I intend to kill tanks. For this one, my choice is still KV 85s. But 3 is not enough! :) I will go for four of them. In the games I played so far (maybe apart from the one against Remer), they had a lot of influence on the outcome of the battle. Their AT12 gun is enough to beat most of the tanks out there and their armor of 9/7/2 allows them to move about and stay in action for a long time. The two main reasons to increase their number from three to four was that I really like what they did in the battles so far and on the other hand I am afraid that a few lucky shots/aircraft runs can inflict early kills and a morale check on my big guys. The last thing I want when I play this company against a tank-heavy force is to quickly loose all my KVs and continue with AT5 through the rest of the game.
But what about recon? The tests that I did were not so positive in terms of BA 10M employment. For my taste, this unit has too many roles to fulfill on the battlefield: recon and secondary anti-tank/anti-gun with their AT of 7, 4+ FP and no H&C. When playing them I always was faced with a situation where I could only use one of their abilities at a time and I paid for all of them. Somebody might say that it is good to have such a toolbox type of unit, but to me: recon is recon - I will not risk it because I have a small chance to punch through the armor of an enemy tank, even if it is a Panther. This is why I decided to go with BA 64s.It is true that they will not be able to handle any real armored units, but on the other hand, they have the advantages of being tiny, easy to hide armored cars with jeep mobility. For anti-ambush screening and lifting gone to ground they are at least enough.
In the games I played there was also one factor missing all the time: even if Tankovy units cannot handle tanks like Panthers or Tigers, I really need a way to at least try to get rid of them. My first thoughts were that I should maybe include 120mm mortars. But these cannot take out a top armor 2 tank and also boost the number of my platoons to 5... In this case, I decided to go for a sporadic I-153 plane support. In all honesty, for 90 points the I-153, which is equipped with 4+ to hit, AT 6, FP 3+ rockets is a brilliant little attack aircraft.
With these modifications my list is now full. Oh, also my commander had to skip his T-34 and take over a T-60 :)
So here it is - my new approach to 1650 Mid War Soviet Tankovy.
CP: 10x T-60
CP: 10x Matilda II CS
SP: 4x KV 85
SP: 4x BA 64
Will test it in 2 weeks' time with my gaming buddy and maybe write a few words on how it went :)