Technically speaking, given a complex enough network and sufficient amounts of time, is it always possible to overfit any dataset to the point where training error is 0?
Neural networks are universal approximators, which pretty much means that as long as there exists a deterministic mapping f from input to output, there always exists a set of parameters (for large enough network) that give you error which is arbitrarly close to minimal possible error, but:
So from mathematical perspective the answer is no, from practical point of view - under the assumption of finite training set and deterministic mapping - the answer is yes.
In particular when you are asking about accuracy of the classification, and you have finite dataset with unique label per datapoint then it is easy to construct by hand a neural network which has 100% accuracy. However this does not mean minimal possible loss (as described above). Thus from the optimization perspective you are not obtaining "zero error".
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