@tamas-kr Thanks for reaching out.
APIM does not have default rate-limit policy and hence usually 429 come from backend or with rate-limit policy defined in API. Based on the request info you shared, 429 errors were returned by backend API (azure Functions) and not APIM.
Limit Doc reference: https://learn.microsoft.com/en-us/azure/azure-resource-manager/management/azure-subscription-service-limits#api-management-limits
As you have already validated that you don't have the rate limit policy. It looks like the request is being rejected from the function app front end and not reaching the function that is the reason you may not see the 429 error at your function app end. Have you tried reviewing the OCP APIM traces reproducing the issue as this will confirm whether APIM is getting 429 error from your backend or not.
I will also suggest to review the Diagnose and solve problems blade on your function app to review if there was SNAT Port Exhaustion issue as this could be one of the reasons for 429 error return to APIM from function app. You can also review other detector in your function app for any issue.