The fuzzy area is that the disposal is a small appliance. The big however is that the receptacle is 1. inaccessable, usually. 2. It serves a fixed appliance so it does not count as one of the required countertop receptacles.
Sometimes the intent of the Code is what the inspector has to consider, as opposed to a specific wording that allows or prohibits a particular installation. The intent of the Code is for the SABC to supply small portable kitchen appliances; coffee pots, toasters, etc. That is why they list only some specific exceptions such as the clock.
Instead of the inspector searcing for the wording that prohibits it ask the electrician to find were it would be allowed.
Alan CEI-M # 138
