That was, if it's the scene I think you're referring to, a specific one-time only powerup that Ichigo was never able to achieve again.
It's not arbitrary...it's specifically contradicted by what's shown. One character says a Gran Ray Cero can destroy las Noches.
Another fires a Gran Ray Cero, and does not destroy Las Noches.
Unless you want to claim Grimmjow was somehow HOLDING BACK against Ichigo...the statements and in-series reality contradict each other. Every Gran Ray Cero fired inflicts fairly minimal destruction.
He's highly resistant, but certainly not immune. He took some superficial damage from both of Soi Fon's bankai attacks.
This implies that a large enough immediate burst of damage, or enough successive bursts of a lower level of damage would be enough to put him down.
I don't think Supes would need any special tricks against Barragan either. Isn't he immune to aging? There's a version of Superman that's like a billion years old or some ****.