Elaborate please. I have alwasy been taught- through PT and nutrition certification- that unless you are a beginner or juicing, this is not possible.
Muscle hypertrophy is a very local process. Goldberg's rats in 1975 showed that hypertrophy could occur even in a large calorie deficit after synergistic ablation. Of course, that's in rats, and synergistic ablation is rather extreme, but it shows that the process is not dependent upon a calorie surplus.
I think it requires a very good diet. When you're in a deficit, the body takes energy not only from stored carbs and fat but also protein. It could also be that protein synthesis, which requires energy, would be inhibited to save energy, but I don't know if that actually happens or if it's just protein break down that increases.
As for studies.. A lot of studies use very low calorie diets and/or don't do resistance training or high protein diets in addition to their calorie deficits, so it's hard to find science to back this up.
I did find this, only abstract, though:
They entered into positive nitrogen balance after 2 weeks in a rater large deficit.
Also this, again, just an abstract, but only group A entered into negative nitrogen balance:
These are only abstracts, though, and the nitrogen balance method isn't the most valid measurement of true nitrogen balance. It has some weaknesses.
In this:
deficits induced by exercise did not lead to a statistically significant loss of muscle size in the lower extremity. Lean mass did decrease, but that doesn't have to be muscle.
Also, none of the participants in the exercise group induced it by resistance training. We can only speculate what would have happened if they had done resistance training.
This abstract from a review claims
Although resistance exercise will not cause an improvement of aerobic performance, increase in muscle size and strength have been noted concurrent with substantial weight loss.
However, I don't have access to the full text there either. These studies were done long ago, so full texts are hard to come by on the net.