Let's take games as an example. You cannot say to users "Just buy more powerful compute/phone". And even if they would you may have literally millions of machines, due to having millions of users. In which case saving 1 dollar worth of machine per user is savings of millions which is worth a lot of developer time. Naturally you as a dev won't really be paying this, so the incentive is not directly there. But the incentive comes from people just not buying a game that runs like crap.
In these cases GC is nice and dandy at start but then you run into the inevitable "Why does my game stutter?", after which object pools are introduced and even then some annoying "leaks" may remain. If the amount of time had been used from the get go to actually think about memory management the whole issue could have been avoided.