Can overclock in windows but not in bios

I know you should use the bios to overclock. However, I can not get the computer to boot after overclocking in the bios. It seems that I can get to 3.6ghz in windows with easy tune 5 but can't get over 3.2ghz in the bios. I am locking the pci at 100mhz, have tried playing with voltages and nothing seems to work.

Pentium 4 540J 3.2g 800mhz
Gigabyte GA-p35-ds3l
2 x Corsair DDR2 XMS2 800mhz

This is in windows and is stable according to Intel Burn Test. However, I can't even get close to this oc in the bios or the computer wont boot past the bios screen.

Is it really 3.6? have you run sandra or other proggy that tells you what speed you are at?
Easy tune could be lying..
Setting memory can be tricky with newer chipsets because there are so many options, and just one setting could potentialy bork your overclock
Have you read the Overclocking the C2D/C2Q sticky yet? there is some usefull info there, and I even learned a few things from it.
Read all you can on the subject, and you might get lucky and have a respectable overclock when you are done.
Good Luck

Edit: you can see the Intel sticky here

I found out I had to set the voltage really high (1.8V) in bios to get it to post. Yet when in windows it only showed 1.44 VCore. This solved the problem.