I would use the sentences in slightly different situations e.g.
a) It is now 10 o'clock. Where is she now? I don't know but she can't have gone to bed. It's only ten o'clock.
b) It is now 11 o'clock. She is in bed. We don't know precisely when she went to bed and we are speculating about the time. She couldn't have gone to bed at ten o'clock because she always eats dinner at 10.15.
In b), I think I would accept "can't" as well but not both options in a).
There might be something in "Advanced Grammar in Use" by Hewings on this, but I haven't checked.