Naraka path does not revive the dead, it just fixes the body, otherwise I think it is obvious that Nagato would have used it to revive Yahiko. All the Pain bodies the ability was used on didn't magically come back to life, they remained as controllable corpses.
Rinne Tensei should have been able to revive him, but Sasuke has no reason to give away his life in the process. Not to mention hat he only had one usable arm and no mastery over one-hand seals at the time and the ability has a time limit within which it can be used as Nagato implied.