LOL, you need to check your squad list a bit. I think I see what you're trying to do, but first of all, 2 Storm Commandos would be 34 points, not 24. And you're missing Nyna from your list.
This is why it's nice to build your squad on Bloomilk or MiniManager and then just copy/paste the squad list.
Overall, it's fairly nice though. I'd be a tad worried that you're depending on just the two Storm Commandos for a lot of your damage though. the TBSV makes a semi-decent 3rd attacker though, so I suppose that works out OK. The other SAK builds have a Noghri Commando instead, which is nice for both the Melee attacker, and the option to tie-up an opponents big piece from getting to your SCs.
I wouldn't necessarily call this a 'counter' to SAK. It's just a variant.
Oh, and the TBSV doesn't have Stealth, so he doesn't get Nyna's CE benefit.