On top of that, even the so-called atomic notes are likely to bear some level of meta information - as opposed to only the note/idea content itself. So an atomic note is usually not really atomic.
One can than argue: you can always put the note/idea in a specific header and refer the header instead with ![[note#header]]. Yes, that is possible, but not practical. If, for example, you change the header name for any reason, all the references to this header become invalid. There is no “header update” feature that visits the whole vault and updates references accordingly.