No, I have not read or heard anywhere of this being an IRS restriction. Having taken the money out for need and receiving the "benefit" of not being penalized for doing so has no bearing on turning around and contributing back in. Totally different "dollars" in tax terms, so to speak. It appears as though you might have found a little loophole. So, to answer your question, no by default as you stated 202 contributions are not to be considered repayments. More like replacement.
