According to developers, Apple has reversed it's previous decision and will now allow Promo Codes to be generated for iTunes App Store apps rated 17+ -- which includes any application that embeds a browser or otherwise allows unfettered access to the internet.
TUAW adds that:
While Apple has not made any official comment on the issue, it appears that they have quietly conceded this battle to the developers, once again enabling them to distribute promo codes as needed for all of their apps.
Promo Codes are the mechanism Apple uses to allow developers of paid apps to generate 50 tickets for free downloads, typically used for give aways or send out review copies. During the brief era of prohibition, everything from Twitter clients to internet data front ends had to either go without, or cut into their beta-testing pool by using some of their 100 ad-hoc build licenses, which still suffer from restrictions all their own.
So, good on Apple, let's keep the problem-solving momentum going.