Yes, anywhere in the node tree. Imagine if CSS was specified in HTML-style. We might write this selector:
h1,
/* don't forget h2! */
h2 {
color: /* I love red */ "red";
}
Like this: <rule>
<selector>
<alternative>
h1
</alternative> <!-- don't forget h2 -->
<alternative>
h2
</alternative>
<selector>
<attributes>
<color><!-- I love red --> red</color>
</attributes>
</rule>
Which is pretty much exactly the same as what you'd get as a CST from parsing the CSS.
Problem is, the CSSOM models that more like this:
Perhaps your takeaway from this is "the CSSOM is bad" (and I don't necessarily disagree), but it's what the "mistake" is talking about.