(5) Receptacle Outlet Location. Receptacle outlets shall be located above, but not more than 500 mm (20 in.) above, the countertop. Receptacle outlets rendered not readily accessible by appliances fastened in place, appliance garages, sinks, or rangetops as covered in 210.52(C)(1), Exception, or appliances occupying dedicated space shall not be considered as these required outlets.
By the words of the NEC, a receptacle inside an appliance garage is not required.
Looking over the ROP's from 2005, though, CMP-2 contradicts itself.
Panel statement in Proposal 2-220 to make appliance garages like sinks and ranges, as breaks in countertop:
The panel does not agree that appliance garages generally split the countertops into separate spaces. The face of the appliance garage
does not typically extend to the outer edge of the countertop; a work surface is available directly in front of the appliance garage that is
contiguous with the counters on either side of the appliance garage.
But then they rejected a proposal to make appliance garages part of the countertop!
Panel statement in response to Proposal 2-224:
Receptacle outlets within appliance garages may be provided as a convenience to the user to allow particular appliances to remain
plugged in while they are stored. They may not be readily accessible for the use of other small appliances such as handheld mixers or
electric carving knives that may not be stored in the garage. GFCI protection is required for all receptacles that serve countertop spaces.
They seem to consider the receptacle inside the garage as needing GFI protection, and serving the countertop. But it's not allowed to be considered serving the countertop.
If they can't get it right, how are we supposed to?