The health ministry did not immediately respond to a Reuters email seeking comment.
Some experts have said excess deaths are the best way to measure the real toll from COVID-19.
"For every country, it's important to capture excess mortality - the only way to prepare the health system for future shocks and to prevent further deaths," Soumya Swaminathan, the chief scientist of the World Health Organization, said on Twitter.
The New York Times said the most conservative estimate of deaths in India was 600,000 and the worst-case scenario several times that. The government has dismissed those figures.
Health experts blame the undercounting largely on scarce resources in the vast hinterland home to two-thirds of India's population of nearly 1.4 billion, and also many deaths at home without being tested.