No, new counter needs to be incremented (+1). Initial value of the counter is 0 (this is given by SHE, considering new device or device reset to factory state). When you are going to load the key first time, you use counter = 1. When you are going to update the key second time, use counter = 2 and so on. If you do not follow this rule, the key won't be updated.
Regards,
Lukas