Spurs are the only Premier League club without a new signing so far this summer, while Ross Barkley remains the only target of lasting interest during a near-barren pre-season.
Comolli has sympathy for Pochettino and Daniel Levy and notes how the club will have to part with record fees for players good enough to crack the current starting XI.
"I think Tottenham deserve so much respect for what they’ve achieved," Comolli told talkSPORT.
"Daniel Levy and Mauricio Pochettino are working with less money than everybody else and working on a lot smaller wage bill than any of the Premier League’s top five - we need to give them some credit.
"I’m sure they know exactly where they’re going [in the transfer market].
He added: "So to reinforce that team with players who are as good or better than those players, and as young too, it’s almost an impossible task.
"They're probably looking for young and up-and-coming players to come an compliment that team, probably two or three and I’m sure they’ll achieve that in the end."
Comolli spent three years at White Hart Lane, between 2005 and 2008, before being sacked ahead of Harry Redknapp's appointment.