User blog comment:FairyRaven/Fairy Tail Chapter 362: Natsu vs. Jackal, Review and Commentary/@comment-7418318-20131201155816/@comment-7418318-20131201173551

Wouldn't it be a bit late to revive her? I mean by now she's got to be a bit... worse for the wear.

I always assumed that the Rinne Tensei could only revive people who died recently, like maybe a few days tops. After all Azuma, who was buried in the city's graveyard and thus should have been within range of the jutsu wasn't revived.

Thus I doubt Obito could bring Konan back (except perhaps as an Edo Tensei zombie, if he managed to learn the spell from watching Kabuto cast it) even if her body was close enough.