I think we have to define goals to measure that statement. I've read a LOT, and I've learned my body and my limits well, and at this moment I would bet anything today that I can meet my current goals in the next year.
Once I'm in the teens bf% wise, I might have to reevaluate those parameters. No, I don't think I'm going to build massive slabs of muscle eating at a deficit, but I'm pretty confident that I can lose weight at a moderate pace(~1 lb a week), while increasing my lbm, I've been doing it consistently for a year and I'm showing no signs of that progress slowing down.
I don't think that my theories on this, and my own progress apply to 'skinny fat' people, and that may be the sticking point of this argument...my caloric demands became high as soon as I increased my activity level due to the amount of weight I carried around.
The statement that "this was possible because you were obese" doesn't invalidate what I've done and am doing, in fact, it just adds another element to the equation.
No training paradigm is right for all trainees, and no diet is right for all dieters, the persons starting physique, body composition and activity level are as important if not more so than all of the 'correct' formulation of programs(usually designed by naturally lean and or muscular people in the first place).