Hi Clint. These are the 2 photos I saw of Ki.54s ( this page and next) with that insignia apparently in a Communications unit; also referenced as such in Barry Kettley's "Emblems of the Rising Sun" as allocated to Utsonomia (and with a red band ). As you say maybe different sections but just guessing.
Nick
http://arawasi-wildeagles.blogspot.c...4-hickory.html