@Longhatruong, thinking about it, I think you're right.
The fact that Amphisbaena is level 5 on land and level 6 in water is inaccurate; Aisha explained it like this: it is considered level 6 by the guild but its real status is level 5, it is given a higher level due to the difficulty of facing it underwater.
What led me to consider it an amphibian was that it was able to get out of the water when it jumped to the ceiling of the 25th floor to launch itself like a kamikaze and make the floor collapse; which means that it can get out of the water but that doesn't make it an amphibian. Sorry for the inaccuracies, I read volume 14 years ago!
That being the case, the parallel you are proposing between Amphisbaena and Leviathan could well be true, if it were the case that adventurers who are not experts in maritime combat had to face it underwater, Leviathan could have a great advantage just like the one Amphisbaena has (one level). But remember that there is the Diving development ability that might well mitigate the effects of the aforementioned advantage, therefore, I would believe that based on this DA it is determined for each particular case how much disadvantage it will have in underwater fights.
There is also the fact that the combat itself could be amphibious, as was the one against Amphisbaena where the Hestia team fought from "land" while the dragon was on the surface of the water. In the case of Leviathan, it could have happened in such a way that those with the Diving AD fought in the water and those without it fought from the deck of the ship, so Leviathan's advantage would not have been constant or universal throughout the fight.
For these reasons, I believe that it should have been a level 10 in order to represent a great challenge for a team with 1 level 9 and perhaps some pseudo level 9s as well, since as I explained previously, it cannot be generalized that the monster had a 1 level boost over all its opponents.