I don't think so, in regular cases. Cell was incapable of receiving a zenkai until all he had left was his core (losing his upper body, or multiple limbs, etc. didn't count), and Boo's regeneration is vastly superior to Cell's - being burned until nothing was left of him but puffs of smoke is basically a temporary inconvenience, after all. And the injuries he sustained after absorbing the half-Saiyans weren't nearly as severe as Cell losing almost all of his body, and, well, an injury more severe than that would require him to nearly fade out of existence.
The only possibility I could think of would be where he was severely beaten by a stronger Boo like Good Boo was, and got knocked out without being able to recover, which may constitute a zenkai since Fatty actually needed healing from Dende that time.