Do 236G and 236H now apply to every kind of goods, or only to the old list of sectors?

A common belief among traders is that sections 236G and 236H only bite on a fixed list of industries such as pharmaceuticals, FMCG, cement and electronics. That was true of the old wording. The consolidated Income Tax Ordinance, 2001 as amended to 30 June 2026 shows that the lists were taken out by the Finance Act, 2024, so both sections now apply by reference to who is selling to whom, not what is being sold.

What does the law say now?

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 Division XIV rate. There is no mention of any sector.

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.

In the consolidated text, a blank footnote marker sits right after “commercial importer” in each section. The footnotes attached to those markers show what used to be there.

What did the old sector lists say?

The footnote to section 236G records that this expression was “omitted by the Finance Act, 2024” (inner amendment markers left out):

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,

The footnote to section 236H records a similar list, also omitted by the Finance Act, 2024. That list does not include fertilizer.

The Finance Act, 2024 itself confirms this. In section 8, which amends the Income Tax Ordinance, clause (35) says that in section 236G(1) the expression naming those sectors “shall be omitted”, and clause (36) does the same for section 236H(1).

Section	Before the Finance Act, 2024	As amended to 30 June 2026
236G(1)	Sales by manufacturers or commercial importers of listed sectors	Sales by any manufacturer or commercial importer
236H(1)	Sales to retailers by manufacturers, distributors, dealers, wholesalers or commercial importers of listed sectors	Sales to retailers by any of them

From when does the wider scope apply?

Section 1(2) of the Finance Act, 2024 says it comes into force “on the first day of July, 2024” unless specified otherwise. Clauses (35) and (36) of section 8 do not specify a different date in the text held here. On that basis the omission took effect from 1 July 2024. The rates for tax year 2027 are those in the Ordinance as amended to 30 June 2026.

What is left unexplained?

Section 236H(1) still contains the words “and every distributor or dealer to another wholesaler in respect of the said sectors”. The footnote records that these words were inserted by the Finance Act, 2015. “The said sectors” referred back to the sector list earlier in the same sub-section. That list has been omitted, but the phrase pointing to it was not.

The Ordinance does not say whether this part of section 236H(1) now covers a distributor’s sales to another wholesaler in every sector, in no sector, or in some other set of sectors. This page does not resolve the question. A reader affected by it should know that the text is incomplete on this point.

Worked example (illustrative figures)

Two businesses in Lahore buy from manufacturers in July 2026. Both are on the Active Taxpayers’ List.

• Hamza Enterprises distributes ceramic tiles, which were never in the old section 236G list.
• Bilal & Sons distributes cooking oil, which was in the old list as “edible oil and ghee”.

Each buys goods worth Rs. 1,500,000 (invented figure). Under the current section 236G(1) both are buying from a manufacturer, so both pay at the Division XIV rate for goods other than fertilizer:

1. Rate: 0.1%.
2. Rs. 1,500,000 x 0.1% = Rs. 1,500 each.

Under the pre-2024 wording, the tile purchase would have been outside the section because tiles were not a listed sector. Under the current wording the answer is the same for both.

What still depends on the kind of goods?

Only the rate, not whether the section applies. Division XIV of Part IV of the First Schedule sets 0.7% for fertilizers and 0.1% for goods other than fertilizers under section 236G. Division XV sets a single 0.5% rate under section 236H. The rates and the higher Tenth Schedule rates are on the related pages.

Common mistakes

• Relying on an old sector list. Guides written before 1 July 2024 describe a limited scope that the Finance Act, 2024 removed.
• Assuming “not listed” means “not covered”. The current sections name no sectors at all.
• Assuming the leftover phrase has a settled meaning. It does not, on the face of the Ordinance.

What to check in the official text

Read sections 236G and 236H with their footnotes in the Ordinance amended to 30 June 2026, and clauses (35) and (36) of section 8 of the Finance Act, 2024. Any later notification or clarification on “the said sectors” is not part of the text held here.