[UIImage imageWithData:]
returns an autoreleased object, which should not be released by you again. So this code snipped contains not a memory leak but the opposite, a double free (in the worst case).
Note that Instruments sometimes generates false positives and/or reports memory leaks in the Foundation itself (yep, they make mistakes too :-).
The fastest way to alloc/release an object is to avoid convenience initializers (like imageWithData:) and instead to something like
NSData* data = [[NSData alloc] initWithContentsOfURL:url]];
UIImage* img = [[UIImage alloc] initWithData:data];
[data release];
// use your image
[img release];
This will allocate and release your object right away and not wait until the autorelease pool is cleaned.
But please note too, that a memory leak is generally not memory that is not yet freed, but that is lost and cannot be freed anymore, so an object which will be deallocated by the autorelease pool is not considered a memory leak.