If that’s true I would say that the NC inspection authority must be way behind the times and incapable of reading and applying the current NEC.
422.31 is completely overwritten by 422.33 if you use the cord and plug connection allowed in 422.16 in compliance with, 400.5, 400.7, 400.8 and 210.21[B][2].
Most appliance manufactures recommend this type of connection. It is easily done and generally considered as a much safer and more professional installation. Once the cord is removed, the appliance is completely disconnected from the power source and there is no unsupported cable of unknown length flapping around below the appliance.
Someone should also explain to them that running a cord though an adjoining cabinet is not restricted by 400.8 because they are not considered walls of the structure.
Some interpret 422.16 to say that you can install the receptacle in the same space occupied by the appliance and not even be able to get at it once the dishwasher is installed and still comply with the definition of accessible in Article 110.
