Be careful what you read. Some hybridizers register a plant with the highest bud count they have got. Instead of averaging the bud count over the scapes and over the years.
With my seedlings I usually aim for a bud count of 15 buds , but I have selected seedlings with less buds because those plant put up more scapes and a lower bud count would not be noticed.
If your selecting for high bud counts you should also be selecting for wide spaced branching and bud placement. Some of the higher bud count plants bloom themselves out very quickly.