If define-syntax introduces a form using with-module, the identifiers within with-module doesn't resolved in respect of with-module.
In fact, it is more like a question of how we treat the interaction between hygiene and with-module. Apparently there are two cases---sometimes we want to preserve identifier's syntactic context regardless of whether it is placed within with-module or not, and sometimes we do want to override the context by the inserted with-module.