Bhaskara I (the less famous of the two Bhaskara) wrote a comment on Aryabhata in 629, where he gives Aryabhata's approximation $\pi\approx {62832\over 20000}=3.1416$, and states that a nonapproximate value for this ratio is impossible.
See Kim Plofker: Mathematics in India, p. 140.
On the surface this would seem like a clear statement equivalent to the irrationality of $\pi$, but perhaps it is not quite so easy. The "reason" Bhaskara gives is that "surds (square roots of nonsquare numbers) do not have a statable size". It is believed that Aryabhata's method of approximating $\pi$ is essentially the same as Archimedes', computing the circumference of an inscribed regular polygon in a circle with 384 sides. This requires the computation of many surds, so perhaps Bhaskara only meant that he could not get an exact value of the circumference of the inscribed polygon.