4. In a contract action, may a claim for money had and received based upon a conversion be brought as a counterclaim under a statute that provides that “in an action on contract, any other cause of action on contract” may be brought as a counterclaim? See Manhattan Egg Co. v. Seaboard Terminal & Refrig. Co., 137 Misc. 14, 242 N.Y.S. 189 (N.Y. City Ct.1929).