Tds on plant and machinery

Respected sir, In respect of TDS on plant and machinery, i am deducting 2% of TDS, but department is alleging it to be 10% and issuing notice again and again, so in revsion of my return what i need to do? whether so it as a 194I or 194IA, if i would clasify as a 194IA in RPU utility the same would be considered as a TDS on sale of immovable property. Please guide me in this regards, Jinal Mehta