Does the DPDP Act require records of processing?
No. The DPDP Act has no equivalent of GDPR Article 30. But section 11(1) gives every Data Principal the right to a summary of their personal data and of everyone it was shared with, and Significant Data Fiduciaries face audits under section 10. Neither is practical to answer without a maintained record of processing.
Anyone telling you otherwise is selling from a GDPR script. See Sec 11(1)(a)–(b) and Sec 10, and how a maintained record of processing activities answers both.
