It stops being an opinion thing when you are working with so many open files that you can't read their names in the tabs. That's why I specifically said "big projects". VS Code gives users the freedom to show files as they want. Atom doesn't.
I work with so many files that I can't read their names in the tabs - so I scroll the list of tabs horizontally - which is exactly what you do I guess if the vertical list doesn't fit on the screen. Or I just find the files again in the project tree. It works fine for me - they can't add everyone's preferred style to the UI or the project would eternally bloat.
So it's just an opinion thing - not objectively terrible as you think.