You actually can if you are overweight and untrained , and I usually see two theories floating around for why this is 1 . A fat person ' s TDEE is higher than that of someone the same size but a healthy weight they need more energy to carry all that fat around . Therefore , even while cutting they are eating at a surplus , and muscle can grow . 2 . A fat person ' s tissue is more insulin resistant , so glucose is ignored by existing tissue while new tissue muscle takes it readily . I would think it ' s a combination of the two , leaning towards insulin resistance being the major factor . As you become closer to a healthy weight , your whole body is hungry for energy and the only way to get it into muscle is if there is a surplus .