during the Zanpakuto Rebellion Muramasa is shown to be able to throw is opponents around and hold them with a form or telekinesis but when he is fighting Ichigo's Inner Hollow in his Inner World he sees a bunch of arms in the reflection of the skyscraper windows which is invisible otherwise and it was them Muramasa was using to hold his Inner Hollow.
when Ichigo and Muramasa fought in Koga's Inner World in Episode 255 Ichigo worked out that Muramsa's ability with those arms only worked where he had a reflective surface like the still water's surface in Koga's Inner World and when the surface was broken by the ripples cause by rubble or Ichigo's attack Muramasa's ability couldn't work.
but when Ichigo first fought Muramasa in Episode 233, before he reached into Ichigo and Zangetsu was put under his control, Muramasa used the same technique to hold Ichigo down, but the main streets of the Seireitei where they fought didn't have any reflective surfaces from what i saw as generally the windows in the barracks and store houses don't have glass but are just holes in the wall with wooden bars sometimes in them.
So where was the reflecting surfaces for Muramasa to use when he ability to hold Ichigo down?