TheNation Monitoring THE HAGUE - India will file its counter-memorial before the Permanent Court of Arbitration (PCA), at The Hague, by November end, in response to Pakistans memorial seeking a complete moratorium on the 330-MW Kishanganga Hydro Electricity Project. India is expected to base its arguments on the provisions of the 1960 Indus Water Treaty, which it claims, allows use of western rivers - Chenab, Jhelum and Indus - for hydro power projects, with certain restrictions, and that India has not violated the treaty. Also, New Delhi is expected to tell the court since Neelum-Jhelum Hydroelectric Project in Azad Kashmir - which Pakistan claims will be affected - is 'India territory occupied by Pakistan, Pakistan cannot raise the Kishenganga project before the PCA. Pakistan had earlier taken the matter to the PCA claiming India had violated the 1960 Indus Water Treaty and the dam would seriously jeopardise Pakistans interest and the Neelum-Jhelum Hydroelectric Project near Muzaffarabad. A seven-judge bench had started arbitration proceedings in the matter in January. In June, Pakistan had sought interim measures from the PCA to ask India to stop all work on the dam.