This is kind of a misleading statement. I guess one could argue if you have a lot of body fat you will likely already be eating in a calorie surplus, so in this sense yes it might be easier to add muscle vs. someone who is in a caloric deficit.
In reality, not much of your body functions in an “ideal” way if you have a ton of body fat. This includes your hormone production of things like hgh and testosterone, which are very big factors in muscle production. So in reality, you are in a much better position to gain muscle around 8-12% body fat than say 20-25%, all else considered equal.
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