In ISO C99, arrays that are not lvalues still decay to pointers, and may be subscripted, although they may not be modified or used after the next sequence point and the unary & operator may not be applied to them. As an extension, GCC allows such arrays to be subscripted in C89 mode, though otherwise they do not decay to pointers outside C99 mode. For example, this is valid in GNU C though not valid in C89:
struct foo {int a[4];}; struct foo f(); bar (int index) { return f().a[index]; }