Sections 31 and 32 apply in respect of proceedings for the refund or recovery of tax paid or purportedly paid as if –

(a) a reference to the Commissioner in those sections, except in section 32(1)(b)(ii) , were a reference to the court; and

(b) a reference to the making of a refund in those sections were a reference to the making of an order or decision that a refund be made.