No, that will not do 
I initially add the data and comments so {data:[ [9, 10, 11, 12, 13, 15, 16]...], cell:[{row: 1, col: 0, comment: {value: '2017'}}...]}
Because of this bug [GH #5661] Why comments are deleted after updating columns?, I have to re-add comments.
But if the filter and sorting is turned on, I cannot add them to the right places.
toVisualRow it helps if only sorting or filter is enabled, but if both sorting and filter are enabled, it returns the wrong index.