Similar problem, if BT headset (Plantronics 975) connected when iPhone 4 is idle, calls seem to be clear both ways, BUT if headset loses connection and needs to re-make during call, or if headset initiates connection after start of call, the caller sounds fine (slightest hiss of static in background, but does not interfere with understanding caller), but caller reports that my audio is awful, "fishbowl" or "intermittently muffled".
This flaw/bug is consistent, verified 5 times in 5 different calls, in 3 different locations, to 3 different callers.
Symptoms were not apparent when using this headset with iPhone 3GS, can't speak to iOS4 on 3GS, did not have long enough to notice problem before switching to iPhone 4.
Symptoms suggest software bug in BT manager, hopefully Apple will fix with 4.1 (hint, hint, Apple...)