If the amount applied by the Commissioner in accordance with section 17 - 20 is more than the amount of the * wine tax credit to which you are properly entitled, the excess is to be treated as if it were wine tax that became payable, and due for payment, by you at the time when it was applied.
Note: The main effect of treating the amount as if it were tax is to apply the collection and recovery rules in Part 3 - 10 in Schedule 1 to the Taxation Administration Act 1953 .