George:
IMHO, this is the key...""Section 210.52(B) requires a minimum of two 20-ampere circuits for all receptacle outlets for the small-appliance loads, including refrigeration equipment, in the kitchen, dining room, pantry, and breakfast room of a dwelling unit."
I have not had anyone debate the issue that a GD or DW should not be on the countertop circuits.
All that said, any discussion about this usually involves a 'modest' kitchen, as opposed to the McMansions, or custom houses that are being built. One condo developement ran the refrig outlet on the SABC, which is OK code wise, & the QC rep from the builder had a canary. Needless to say, the guy who OKs the checks got his 12/2 frig circuit in the end. These units had a DW circuit & a GD circuit, a micro circuit & 2 SABCs in each kitchen.
Another angle is what is the HP/amperage of the GD? I've seen some that are 11.5 amps.
Take care & stay safe.
