Saiyans can only get Zenkais when their near death. Basically if a Saiyan his ass beaten and survives, he gets a zenkai. If he dies and somehow gets revived then he didn't get one because he died, not almost dying and getting that zenkai.
Logically, he shouldn't. But, anime wise, everything makes more sense if we accept that he does every time he dies or gets revived:
-His performance against Pikuhan.
-His SSJ3 being seemingly stronger against Kid Buu than it was against Fat Buu.