I had to have 4 ft. of sch. 40 covered in 2" of concrete in a garage on a new 200 amp remodel because the H.O. decided to make some changes post bid to his kitchen wall. He paid of course but was not happy with the inspector's decision, I told the H.O. what would probably happen. The other option (more costly) was to put a 200 amp service disco. outside the house. The inspector confirmed that there is no actual distance called out in the code but that the most consistent interpretation is that the panel be located as close as possible to the point of entrance to the home.