Applicant Ron Ford says while the takeaway at the Oasis on Royal Albert Drive has been "very successful", the restaurant upstairs has struggled to be financially viable and has been closed for years.
He is applying to turn the first floor into self-contained holiday accommodation and adding a mezzanine to create two bedrooms.
There has only been one objection, which states that the site "is part of open public gardens and not the right place for such a development".
The objector added: "There should be no accommodation built on the Marine Drive. Holiday or residential.
"This could be the start of many applications. Where would it end?"
However planners are recommending that councillors give the plans the green light at a meeting at Spa Grand Hall on Thursday May 12.
They said the change of use wouldn't affect the conservation area as the building would not be altered externally.
They stated: "The site will retain the takeaway facility that remains viable."