As I see the issue I see with counting ToC entries is that there's lots of non-ToC entries.
Okay then, you say, just count the actual entries that have numbers—except some ToCs don't bother with numbers, and sometimes there are numbers but also an unnumbered prologue/epilogue.
Personally, I do it manually - copy ToC (ebook-viewer lets you do this) to a text editor, remove unwanted lines, check number of lines.
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