Whenever a movement is in the case, a certain amount of pressure will be on the movement due to the movement holders pressing and holding it place. This CAN cause the timing to change in comparison to a caseless movement. This is one of the reasons why I usually do not adjust a movements timing and beat error while it is not yet cased. On certain movements I adjust the timing twice at least, once caseless and once when it's fully cased.
Now when it comes to a caseback, this will not or should not have impact on the timing. Just make sure that when you compare the timings of caseback on VS caseback off is that the watch is in the same position. So in both situations dial down. Plus you can only adjust a timing in dial down position.