On one hand I agree, on the other hand I just know that some people would immediately abuse it and put relevant data into comments.
This is why there are none, but I still think it’s dumb. Parsers can’t see comments anyways.
I have actually seen it in an XML file in the wild. Never quite understood why they did it. Anything they encoded into there, they could have just added a node for.
But it was an XML format that was widely used in a big company, so presumably somewhere someone wrote a shitty XML parser that can’t deal with additional nodes. Or they were just scared of touching the existing structure, I don’t know.