Do sections 236G and 236H still apply only to listed sectors like pharma, FMCG and cement, or to all goods?

Until 2024, a trader could check whether sections 236G and 236H touched its business by reading a list of sectors in the section itself. That list is gone. For tax year 2027 the sections read without any sector restriction, which means a trader in stationery, crockery or spare parts has to read them the same way as one in cement or cooking oil.

What did the sections used to say?

Clause (35) of section 8 of the Finance Act, 2024 sets out the expression it omitted from section 236G(1):

“of pharmaceuticals, poultry and animal feed, edible oil and ghee, auto-parts, tyres, varnishes, chemicals, cosmetics, IT equipment, electronics, sugar, cement, iron and steel products, fertilizer, motorcycles, pesticides, cigarettes, glass, textile, beverages, paint or foam sector,”

Clause (36) omits the same list from section 236H(1), with one difference: it does not include “fertilizer”. The footnotes to both sections in the Ordinance amended to 30 June 2026 reproduce these words and record that they were “omitted by the Finance Act, 2024”.

Note that “FMCG” was never one of the listed words. The list named product groups such as edible oil and ghee, cosmetics and beverages.

What do the sections say now?

With the list removed, section 236G(1) reads: every manufacturer or commercial importer, at the time of sale to distributors, dealers and wholesalers, “shall collect advance tax at the rate specified in Division XIV of Part IV of the First Schedule”. The site text shows the gap where the list used to be as “3[ ]”.

Section 236H(1) reads: every manufacturer, distributor, dealer, wholesaler or commercial importer, at the time of sale to retailers, “and every distributor or dealer to another wholesaler in respect of the said sectors”, shall collect advance tax at the Division XV rate.

Neither section now names a product. On their words, they apply to sales of goods by the named sellers to the named buyers whatever the goods are.

Do the rate schedules still separate goods?

Only in one respect. Division XIV of Part IV of the First Schedule, which sets the 236G rate, still has two categories:

Category of sale	Rate under Division XIV
Fertilizers	0.7%
Other than fertilizers	0.1%

A proviso sets 0.25% for fertilizer sold to buyers on both the sales tax and income tax Active Taxpayers’ Lists.

Division XV, which sets the 236H rate, has a single rate: 0.5% “on the gross amount of sales”. The earlier version with a separate 1% rate for electronics was substituted by the Finance Act, 2021.

Worked example (illustrative figures)

Awan Crockery House in Rawalpindi is a wholesaler that buys dinner sets directly from a local manufacturer and sells them to shops. Crockery was never on the omitted list. For tax year 2027, with invented amounts and both buyers on the Active Taxpayers’ List:

1. It buys Rs. 2,000,000 of crockery from the manufacturer. Section 236G at 0.1%: Rs. 2,000,000 x 0.1% = Rs. 2,000, collected by the manufacturer from Awan Crockery House.
2. It sells Rs. 600,000 of crockery to a retail shop. Section 236H at 0.5%: Rs. 600,000 x 0.5% = Rs. 3,000, collected by Awan Crockery House from the shop.

Before the Finance Act, 2024, crockery sat outside the listed sectors. As the sections now read, nothing in their words takes crockery out.

What is the problem with “the said sectors”?

The second limb of section 236H(1), inserted by the Finance Act, 2015, covers sales by “every distributor or dealer to another wholesaler in respect of the said sectors”. “The said sectors” pointed back to the list earlier in the same sub-section. The Finance Act, 2024 omitted that list but, as the consolidated text shows, left this phrase in place.

So the phrase now refers to sectors that the section no longer names. The text does not say whether the second limb:

• now covers distributor or dealer sales to wholesalers in all goods, the same as the first limb; or
• covers nothing, because there are no “said sectors” left to refer to.

The Ordinance does not resolve this, and this page does not resolve it either. A distributor or dealer selling to other wholesalers is dealing with wording that is, on its face, unclear.

Common mistakes

• Relying on an old sector list. Guidance written before the Finance Act, 2024 describes a narrower section.
• Assuming 236H has a sector-based rate. Division XV has one rate of 0.5%. Only Division XIV for 236G still separates fertilizer.
• Reading “the said sectors” as settled. It is leftover wording, and its effect after the omission is not stated in the text.

What to check in the official text

Read sections 236G and 236H with their footnotes in the Income Tax Ordinance amended to 30 June 2026, and clauses (35) and (36) of section 8 of the Finance Act, 2024. Read Divisions XIV and XV of Part IV of the First Schedule for the current rates. Check for any later amendment, clarification or notification that deals with the words “the said sectors”.