It's pretty obvious that a pissed off Juggernaut is going to be able to do more impressive feats than a Juggernaut who looks like he's seen a ghost when War Hulk stopped him in his tracks.
I think some odd 40-50 pages ago I constantly put up the arguement that Juggernaut has "limitless" strength because he has never been shown to be physically "too weak" to do a task. I dropped that arguement a while ago, but if you consider the times when Juggernaut gets pissed off......he does actually show himself to be limitless in strength. (only because no one has made him max out...to date)