Trivial example of platform where that is relevant is 16b 8086 with anything but tiny memory model (ie. CS=DS=SS). Somewhat more relevant are various Harvard-ish embedded platforms with separate RAM/ROM address spaces. In both cases there are C implementations that are used in production applications.
Another reason for this rule (and probably the original one) are various platforms with segmentation based fine-grained memory protection. That means either things like Burroughs large systems or running C on top of some kind of VM while preserving the underlying memory management. And there are C implementations for that kinds of environments (That most of the existing C code is not directly compatible with that kind of implementation is another thing).
If C was just memory, the only operations allowed would be on and through memory addresses, and values wouldn't be first class.